Tyler v. Cain

PETITIONER: Tyler
RESPONDENT: Cain
LOCATION: Florida Supreme Court

DOCKET NO.: 00-5961
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 533 US 656 (2001)
ARGUED: Apr 16, 2001
DECIDED: Jun 28, 2001

ADVOCATES:
Charles E. F. Heuer - New Orleans, Louisiana, argued the cause for the respondent
Herbert V. Larson, Jr. - Argued the cause for the petitioner
James A. Feldman - Department of Justice, argued the cause for the respondent

Facts of the case

Melvin Tyler was convicted of second-degree murder. Ultimately, Tyler filed his sixth state habeas petition after the U.S. Supreme Court decided Cage v. Louisiana, which held that a jury instruction is unconstitutional if there is a reasonable likelihood that the jury understood it to allow conviction without proof beyond a reasonable doubt. Tyler claimed that that a jury instruction in his trial was similar to the one ruled unconstitutional in Cage. Ultimately, Tyler filed a second federal habeas petition pursuant to the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The District Court denied relief. In affirming, the Court of Appeals stated the District Court had failed to determine whether Tyler had satisfied the AEDPA's successive habeas standard, which requires a district court to dismiss a claim in a second or successive application unless the applicant "shows" that the "claim relies on a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable." The court concluded that Tyler did not meet this standard because he "could not show that any Supreme Court decision renders the Cage decision retroactively applicable to cases on collateral review."

Question

Was the ruled established under Cage v. Louisiana, that a jury instruction is unconstitutional if there is a reasonable likelihood that the jury understood the instruction to allow conviction without proof beyond a reasonable doubt, "made retroactive to cases on collateral review by the Supreme Court," such that an inmate is entitled to submit successive a habeas petition based on that new rule?

Media for Tyler v. Cain

Audio Transcription for Oral Argument - April 16, 2001 in Tyler v. Cain

Audio Transcription for Opinion Announcement - June 28, 2001 in Tyler v. Cain

Clarence Thomas:

I have the opinion in Tyler versus Cain, No. 00-5961.

This case comes to us on a writ of certiorari to the United States Court of Appeals for the Fifth Circuit.

Petitioner Tyler was convicted of second degree murder for killing his 20-day-old daughter.

After he unsuccessfully flawed federal habeas relief, this Court decided Cage v. Louisiana.

Under Cage, a jury instruction in unconstitutional, if there is a reasonable likelihood that the jury understood the instruction to allow conviction without proof beyond the reasonable doubt.

Claiming that jury instruction at his trial, was virtually identical to the one invalidated in Cage.

Tyler sought and received permission to file a second habeas petition.

The District Court addressed the merits of Tyler’s claim and denied relief.

On Appeal the Fifth Circuit affirmed, it stated however, that the District Court erred by failing first to determine whether Tyler satisfied certain requirements in the Antiterrorism and Effective Death Penalty Act of 1996 that are applicable to second habeas petitions.

This Act requires a District Court to dismiss the claim in a second petition unless as relevant here, the applicant shows that the claim relies on a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court.

The Fifth Circuit concluded that Tyler did not meet the standard because the Supreme Court never made the Cage rule retroactive to cases on collateral review.

In an opinion filed with the Clerk today, we affirm.

A new rule is not made retroactive by this Court, unless we hold it to be retroactive.

Although the word “made” might be ambiguous out of context, its meaning is clear in the context of the statute, because “made” means held, it follows that this Court has not made the rule in Cage retroactive to cases on collateral review.

Cage itself held only that the particular jury instruction at issue was unconstitutional, and although we determined in Sullivan v. Louisiana that a Cage error is structural error.

That holding is not equivalent to a holding that Cage is retroactive.

We have never held that all structural error rules are retroactive.

Justice O’Connor has filed a concurring opinion; Justice Breyer has filed a dissenting opinion which Justices Stevens, Souter, and Ginsburg join.