Felker v. Turpin Case Brief

Why is the case important?

The Defendant, Ellis Wayne Felker (Defendant), while on death row, twice petitioned the federal courts for a writ of habeas corpus. While his second petition was pending, Congress passed the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”).

Facts of the case

“Ellis Felker filed a petition for writ of habeas corpus, appellate or certiorari review, and stay of execution after having his convictions for capital murder, rape, aggravated sodomy, and false imprisonment affirmed on appeal. Felker’s habeas petition challenged the constitutionality of Title I of the Antiterrorism and Effective Death Penalty Act of 1996 (the “”Act””). Title I of the Act requires that all motions for filing a second or successive habeas appeal from a district court be reviewed by an appellate panel whose decision shall not be appealable by writ of certiorari to the Supreme Court.”

Question

Is the AEDPA a constitutional exercise of Congress’s power to limit the Supreme Court’s jurisdiction under the Exceptions and Regulations Clause of the Constitution?

Answer

Yes. Petition denied for want of jurisdiction. The Supreme Court notes that the AEDPA does not remove jurisdiction of the Court to entertain original petitions for writs of habeas corpus, but only limits (defines exceptions to) its appellate jurisdiction over subsequent petitions.

Conclusion

The court denied the application. The court held that under pre-Act law concerning second or successive petitions, petitioner was unable to establish cause and prejudice sufficient to excuse his failure to have presented his claims in his first habeas petition and that petitioner’s claims did not fall within the narrow class of cases implicating a fundamental miscarriage of justice. He had not presented claims that relied on a new rule of law, made retroactive to cases on collateral review, which was previously unavailable and that petitioner was otherwise unable to meet the requirements for leave to file successive habeas petitions.

  • Case Brief: 1996
  • Petitioner: Felker
  • Respondent: Turpin
  • Decided by: Rehnquist Court

Citation: 518 US 651 (1996)
Argued: Jun 3, 1996
Decided: Jun 28, 1996