Mayle v. Felix

PETITIONER: Deneice A. Mayle, Warden
RESPONDENT: Jacoby Lee Felix
LOCATION: Texas State Capitol

DOCKET NO.: 04-563
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 545 US (2005)
GRANTED: Jan 07, 2005
ARGUED: Apr 19, 2005
DECIDED: Jun 23, 2005

ADVOCATES:
David M. Porter - argued the cause for Respondent
Lisa Schiavo Blatt -
Lisa S. Blatt - argued the cause for Petitioner
Matthew K.M. Chan - argued the cause for Petitioner

Facts of the case

A California state court sentenced Felix to life in prison for murder. Felix's conviction became final on August 12, 1997. Federal habeas law gave Felix one year to file a habeas petition in federal court. On May 8, 1998, Felix filed a habeas petition and asserted a Sixth Amendment challenge to the admission into his trial of videotaped prosecution witness testimony. On January 28, 1999, more than five months after the one-year habeas time limit, Felix filed an amended petition arguing that the admission into his trial of pretrial statements had violated the Fifth Amendment. Felix argued that the one-year limit did not bar this amended petition, citing the rule under federal habeas law that amended petitions relate back to the filing date of the original petition if both arise out of the original's "conduct, transaction or occurrence." Because his Fifth and Sixth Amendment claims challenged the same criminal conviction, Felix argued, they arose out of the same "conduct, transaction, or occurrence." The district court disagreed and ruled the amended petition time barred; the court rejected the Sixth Amendment claim on its merits. The Ninth Circuit affirmed the Sixth Amendment ruling, but agreed with Felix that his amended petition was not time barred because they both arose out of the same trial and conviction.

Question

Federal habeas law allowed an amended petition to relate back to the filing date of the original petition if both arose out out of the same "conduct, transaction or occurrence" the original set forth. Did the trial and conviction qualify as a "conduct, transaction or occurrence?"

Media for Mayle v. Felix

Audio Transcription for Oral Argument - April 19, 2005 in Mayle v. Felix

Audio Transcription for Opinion Announcement - June 23, 2005 in Mayle v. Felix

Ruth Bader Ginsburg:

The second case I have to announce is Mayle v. Felix, No. 04-563.

This case involves a state prisoner who petitioned for habeas corpus relief in Federal Court.

Congress has imposed a strict time limit on habeas petitions one year from the date the conviction became final.

If a prisoner petitions on time, may he add after the time limit has run new claims that differ in time and type from the claim he originally raised.

We hold that he may not.

Once a time limit has run, new claims can be added to a habeas petition only if they are related in time and type to the occurrences identified in the initial timely petition.

Respondent, Felix was convicted of grave felonies in California State Court and was sentenced to life imprisonment.

His current application for federal habeas relief sent us on two alleged Trial Court errors, each involved the admission of out of court statements during the prosecutor's case in chief, but the two are otherwise, unrelated.

One alleged error concerned inculpatory statements Felix made during pretrial police interrogation.

Those statements, he objected were coerced and therefore their admission at trial violated his Fifth Amendment privilege against self incrimination.

The other alleged error involved a videotape of pretrial statements made by a prosecution witness.

Admission of the videotape, Felix objected, violated his Sixth Amendment right to confront the witnesses against him.

Felix's conviction was affirmed on appeal and became final in August 1997.

Under the one year time limit imposed by federal law, Felix had until August 1998 to file a federal habeas petition.

On May 1998, Felix timely filed a habeas petition asserting his Confrontation Clause challenge to the admission of the videotape witness statement.

The Federal Court in which he filed his petition promptly appointed counsel to represent him.

Eight months later and over five months after the expiration of the time allowed for filing a habeas petition, Felix filed an amended petition.

In it, he added to the Confrontation Clause challenge, a Fifth Amendment challenge to the admission of Felix's own pretrial statements.

The state urged that Felix's Fifth Amendment claim was asserted too late.

Federal Rule of Civil Procedure 15 controls that matter of time.

Rule 15 governs pleading amendments in civil litigation and Congress has made it applicable to habeas proceedings.

Rule 15(c)(2) permits an untimely pleading amendment to relate back to the filing date of the original pleading and thus escape a statute of limitations bar if and only if both the original plea and the amendment arise out of the same conduct, transaction, or occurrence set forth in the original pleading.

Felix urged that his Confrontation Clause and Fifth Amendment claims though factually unrelated, arose from the same conduct, transaction, or occurrence thus meeting the Rule 15(c)(2) requirement because both claims challenged the constitutionality of the same criminal conviction.

The Court of Appeals for the Ninth Circuit agreed holding that the relevant transaction for purposes of Rule 15(c)(2) was the entire State Court proceeding including Felix's trial conviction and sentencing.

We now reverse.

Under the Ninth Circuit's comprehensive definition of Rule 15(c)(2)'s conduct, transaction, or occurrence language, virtually any new claim introduced in an amended habeas petition will relate back to a federal habeas claims necessarily challenged the constitutionality of a conviction or sentence.

Looking to the run of the mind civil proceedings that Rule 15(c)(2) ordinarily governs, the Court has found no reading of conduct, transaction, or occurrence as capacious as the Ninth Circuit's construction.

Decisions applying Rule 15(c)(2) in civil litigation show that the rule relaxes but does not obliterate the statute of limitations to ease up on but still respect a legislated time bar relation back must depend on the existence of a common core of operative facts that unites the original and newly asserted claims.

Felix's Fifth Amendment claim challenging the admission of his own pretrial statements tardily raised in his amended petition does not in our view relate back to the Confrontation Clause claim asserted in Felix's original petition.

Although both claims challenge the legality of Felix's custody, the claims rest on no common core effects.