Mayle v. Felix

545 U.S. 644, 125 S. Ct. 2562, 162 L. Ed. 2d 582, 2005 U.S. LEXIS 5016
CourtSupreme Court of the United States
DecidedJune 23, 2005
Docket04-563
StatusPublished
Cited by1,890 cases

This text of 545 U.S. 644 (Mayle v. Felix) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mayle v. Felix, 545 U.S. 644, 125 S. Ct. 2562, 162 L. Ed. 2d 582, 2005 U.S. LEXIS 5016 (2005).

Opinions

[648]*648Justice Ginsburg

delivered the opinion of the Court.

This case involves two federal prescriptions: the one-year limitation period imposed on federal habeas corpus petitioners by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U. S. C. § 2244(d)(1); and the rule that pleading amendments relate back to the filing date of the original pleading when both the original plea and the amendment arise out of the same “conduct, transaction, or occurrence,” Fed. Rule Civ. Proc. 15(c)(2).

Jacoby Lee Felix, California prisoner and federal habeas petitioner, was convicted in California state court of first-degree murder and second-degree robbery, and received a life sentence. Within the one-year limitation period AEDPA allows for habeas petitions, Felix filed a pro se petition in federal court. He initially alleged, inter alia, that the admission into evidence of videotaped testimony of a witness for the prosecution violated his rights under the Sixth Amendment’s Confrontation Clause. Five months after the expiration of AEDPA’s time limit, and eight months after the federal court appointed counsel to represent him, Felix filed [649]*649an amended petition in which he added a new claim for relief: He asserted that, in the course of pretrial interrogation, the police used coercive tactics to obtain damaging statements from him, and that admission of those statements at trial violated his Fifth Amendment right against self-incrimination. The question presented concerns the timeliness of Felix’s Fifth Amendment claim.

In ordinary civil proceedings, the governing Rule, Rule 8 of the Federal Rules of Civil Procedure, requires only "a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. Rule Civ. Proc. 8(a)(2). Rule 2(c) of the Rules Governing Habeas Corpus Cases requires a more detailed statement. The habeas rule instructs the petitioner to “specify all the grounds for relief available to [him]” and to “state the facts supporting each ground.”1 By statute, Congress provided that a habeas petition “may be amended ... as provided in the rules of procedure applicable to civil actions.” 28 U. S. C. §2242. The Civil Rule on amended pleadings, Rule 15 of the Federal Rules of Civil Procedure, instructs: “An amendment of a pleading relates back to the date of the original pleading when . . . the claim . . . asserted in the amended pleading arose out of the conduct, transaction, or occurrence set forth or attempted to be set forth in the original pleading.” Fed. Rule Civ. Proc. 15(c)(2).

The issue before us is one on which federal appellate courts have divided: Whether, under Federal Rule of Civil Procedure 15(c)(2), Felix’s amended petition, filed after AEDPA’s one-year limitation and targeting his pretrial statements, relates back to the date of his original timely filed petition, which targeted the videotaped witness testimony. Felix urges, and the Court of Appeals held, that the [650]*650amended petition qualifies for relation back because both the original petition and the amended pleading arose from the same trial and conviction. We reverse the Court of Appeals’ judgment in this regard. An amended habeas petition, we hold, does not relate back (and thereby escape AEDPA’s one-year time limit) when it asserts a new ground for relief supported by facts that differ in both time and type from those the original pleading set forth.

I

In 1995, after a jury trial in Sacramento, California, respondent Jacoby Lee Felix was found guilty of murder and robbery stemming from his participation in a carjacking in which the driver of the car was shot and killed. App. E to Pet. for Cert. 2-7. He was sentenced to life imprisonment without the possibility of parole. App. C to Pet. for Cert. 1-2. The current controversy centers on two alleged errors at Felix’s trial. Both involve the admission of out-of-court statements during the prosecutor’s case in chief, but the two are otherwise unrelated. One prompted a Fifth Amendment self-incrimination objection originally raised in the trial court, the other, a Sixth Amendment Confrontation Clause challenge, also raised in the trial proceedings.

Felix’s Fifth Amendment claim rested on the prosecution’s introduction of statements Felix made during pretrial police interrogation. These statements were adduced at trial on direct examination of the investigating officer. Felix urged that the police used coercive tactics to elicit the statements. Id., at 8-9. His Sixth Amendment claim related to the admission of the videotaped statements prosecution witness Kenneth Williams made at a jailhouse interview. The videotape records Williams, a friend of Felix, telling the police that he had overheard a conversation in which Felix described the planned robbery just before it occurred. When Williams testified at trial that he did not recall the police interview, the trial court determined that Williams’ loss of [651]*651memory was feigned, and that the videotape was admissible because it contained prior inconsistent statements. App. E to Pet. for Cert. 10-13.

On direct appeal, Felix urged, inter alia, that the admission of Williams’ videotaped statements violated Felix’s constitutional right to confront the witnesses against him. He did not,, however, argue that admission of his own pretrial statements violated his right to protection against self-incrimination. The intermediate appellate court affirmed Felix’s conviction and sentence, id., at 10-13,17, and the California Supreme Court denied his petition for review, App. F to Pet. for Cert. 2. Felix’s conviction became final on August 12,1997. App. C to Pet. for Cert. 10.

Under AEDPA’s one-year statute of limitations, Felix had until August 12, 1998, to file a petition for a writ of ha-beas corpus in federal district court. See § 2244(d)(1)(A). Within the one-year period, on May 8,1998, he filed a pro se petition for federal habeas relief. Felix’s federal petition repeated his Sixth Amendment objection to the admission of the Williams videotape, but he again failed to reassert the objection he made in the trial court to the admission of his own pretrial statements. App. G to Pet. for Cert. 1-7. On May 29,1998, a Magistrate Judge appointed counsel to represent Felix. App. C to Pet. for Cert. 6; App. H to Pet. for Cert. 2. Thereafter, on September 15,1998, the Magistrate Judge ordered Felix to file an amended petition within 30 days. Id., at 3. On Felix’s unopposed requests, that period was successively extended. Id., at 4-5. Pending the filing of an amended petition, the State was not required to interpose an answer.

On January 28, 1999, over five months after the August 12, 1998 expiration of AEDPA’s time limit, and eight months after the appointment of counsel to represent him, Felix filed an amended petition.

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545 U.S. 644, 125 S. Ct. 2562, 162 L. Ed. 2d 582, 2005 U.S. LEXIS 5016, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayle-v-felix-scotus-2005.