Deneice A. Mayle, Warden v. Jacoby Lee Felix (545 U.S. 644)
U.S. Supreme Court · decided June 23, 2005 · Supreme Court Database (Spaeth)
- Citation
- 545 U.S. 644 · 125 S. Ct. 2562
- Decided
- June 23, 2005
- Term
- October Term 2004
- Vote
- 7–2
- Majority author
- Justice Ginsburg
- Issue area
- Criminal Procedure
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice 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 an 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…
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