Tyler v. Cain

Supreme Court of the United States · 2001 · Federal Courts

Federal CourtsHabeas CorpusAEDPARetroactivityAEDPAsuccessive habeas petitionsretroactivitynew rule of constitutional law

Facts

Tyler was convicted of second-degree murder after shooting and killing his 20-day-old daughter in 1975. After this Court decided Cage v. Louisiana, Tyler argued that the reasonable-doubt instruction at his trial was substantively identical to the instruction condemned in Cage. He later sought to pursue that claim in a second federal habeas application under AEDPA. The key dispute was whether Cage had been made retroactive to cases on collateral review by the Supreme Court, as required by 28 U.S.C. § 2244(b)(2)(A).

Issue

For purposes of AEDPA's restriction on second or successive habeas petitions, when is a new rule of constitutional law 'made retroactive to cases on collateral review by the Supreme Court'? Specifically, had the Supreme Court made the rule announced in Cage retroactive within the meaning of § 2244(b)(2)(A)?

Rule

Under 28 U.S.C. § 2244(b)(2)(A), a claim in a second or successive habeas application qualifies only if it relies on a new rule of constitutional law that the Supreme Court itself has held retroactive to cases on collateral review. A rule may be made retroactive through multiple Supreme Court holdings, but only when those holdings necessarily dictate retroactivity; it is not enough that the Court's reasoning or general retroactivity principles suggest that retroactive application would be appropriate.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Darnell Price was convicted in Missouri in 1994. After losing his first federal habeas petition, he seeks authorization to file a second petition based on a new constitutional rule announced by the Supreme Court in 2023. Several later Supreme Court opinions praise the rule as essential to fair trials, but none says the rule applies retroactively on collateral review.

If Darnell files the second petition, which is the strongest argument for dismissal under 28 U.S.C. § 2244(b)(2)(A)?

Explanation. Section 2244(b)(2)(A) requires that the new rule be made retroactive to cases on collateral review by the Supreme Court. The majority construed "made" to mean "held." So a prisoner's claim cannot proceed on a second or successive petition merely because Supreme Court reasoning suggests retroactivity; there must be a holding by the Supreme Court, or multiple holdings that necessarily dictate that result.