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Mayle v. Felix

Supreme Court of the United States · 2005 · Civil Procedure

Civil ProcedureHabeas CorpusRelation BackAEDPA Statute of LimitationsRule 15(c)(2)relation backAEDPA28 U.S.C. 2244(d)(1)

Facts

Felix was convicted in California state court of murder and robbery. In his timely pro se federal habeas petition, he claimed that admission of witness Kenneth Williams's videotaped statements violated the Confrontation Clause. More than five months after AEDPA's one-year deadline expired, Felix amended the petition to add a claim that his own statements to police had been coerced and their admission at trial violated the Fifth Amendment. The two claims involved different out-of-court statements and different events: Williams's jailhouse interview and Felix's separate police interrogation.

Issue

Whether, under Federal Rule of Civil Procedure 15(c)(2), a habeas petition amended after AEDPA's one-year limitations period may relate back when the new claim arises from the same trial and conviction as the original timely claim, even though it depends on different underlying facts. More specifically, did Felix's Fifth Amendment coerced-statements claim relate back to his original Confrontation Clause claim?

Rule

An amended habeas petition does not relate back under Rule 15(c)(2) when it asserts a new ground for relief supported by facts that differ in both time and type from those set forth in the original pleading. Relation back is proper only when the original and amended habeas claims are tied to a common core of operative facts, not when they merely attack the same trial, conviction, or sentence.

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In Phoenix, Omar Nasser timely filed a federal habeas petition alleging that the prosecution suppressed a detective's field notes from a March 3 apartment search. After AEDPA's one-year period expired, appointed counsel amended the petition to allege that the same nondisclosure also violated due process because one page of those same field notes showed a different suspect description.

Should the amended claim relate back to the timely petition?

Explanation. Relation back in habeas is proper when the original and amended claims share a common core of operative facts. Here both claims center on the same detective notes from the same search and the same alleged nondisclosure. The amendment does not depend on a separate episode differing in time and type; it elaborates on the same factual occurrence. (Derived from Mayle v. Felix (n.d.).)