Woodford v. Garceau

PETITIONER: Woodford
RESPONDENT: Garceau
LOCATION: United States Court of Appeals for the Ninth Circuit

DOCKET NO.: 01-1862
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 538 US 202 (2003)
ARGUED: Jan 21, 2003
DECIDED: Mar 25, 2003

ADVOCATES:
Janis S. McLean - Sacramento, California, argued the cause for the petitioner
Lynne S. Coffin - San Francisco, California, argued the cause for the respondent

Facts of the case

In Lindh v. Murphy, 521 U.S. 320, the U.S. Supreme Court held that amendments to the criminal code made by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) do not apply to cases pending in federal court on the AEDPA's effective date, April 24, 1996. Robert Garceau was convicted of first-degree murder and sentenced to death. After his petition for state postconviction relief was denied, Garceau moved for the appointment of federal habeas counsel and a stay of execution in Federal District Court on May 12, 1995. He filed a federal habeas application on July 2, 1996. The District Court concluded that Garceau's habeas application was not subject to AEDPA because his motions for counsel and a stay were filed prior to that date. The Court of Appeals agreed.

Question

Is a federal habeas petition, which was filed after the effective date of the Antiterrorism and Effective Death Penalty Act of 1996 even though a stay and counsel were sought prior to that date, "pending" for the purposes of Lindh v. Murphy, 521 U.S. 320?

Media for Woodford v. Garceau

Audio Transcription for Oral Argument - January 21, 2003 in Woodford v. Garceau

Audio Transcription for Opinion Announcement - March 25, 2003 in Woodford v. Garceau

William H. Rehnquist:

The opinion of the Court in No. 01-1862, Woodford against Garceau will be announced by Justice Thomas.

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

In Lindh versus Murphy, we held that the Antiterrorism and Effective Death Penalty Act of 1996 does not apply to cases already pending in Federal Court on April 24, 1996.

That was the effective date.

In this case, we consider when a capital habeas case becomes pending for purposes of the rule announced in Lindh.

Respondent brutally killed his girlfriend and her 14-year-old son.

He was convicted of first-degree murder and was sentenced to death.

After California Courts denied his request for post conviction relief, respondent turned to the Federal Courts filing a motion for appointment of federal habeas counsel and an application for stay of execution.

Subsequently, respondent filed an actual habeas corpus application.

The District Court concluded that because the motion for counsel and the stay application had been filed before AEDPA's effective date, the respondent’s habeas application was not subject to AEDPA, even though the application itself had been filed after AEDPA became effective.

The Court of Appeals for the Ninth Circuit agreed departing from the conclusion reached by five other Courts of Appeals.

In an opinion filed with the Clerk today, we reverse the judgment of the Court of Appeals for the Ninth Circuit and remand for further proceeding.

AEDPA places heavy emphasis on the standards governing the review of the merits of the habeas application, and the rule announced in Lindh should be interpreted in light of this emphasis.

Accordingly, AEDPA does not apply if on AEDPA’s effective date, a state prisoner had before Federal Court a habeas petition seeking an adjudication on the merits of the petitioner’s claims.

By contrast, however, an application filed after AEDPA’s effective date should be reviewed under AEDPA even if other filings by that same applicant such as a request or appointment of counsel or a motion for stay of execution were presented to a Federal Court prior to AEDPA’s effective date.

I am sure you got all of that.

One of my colleagues said that this case is about how AEDPA violates ERISA.

I am not going to say which of my colleagues but he sits to my left.

Here, respondent’s habeas corpus application was not filed in Federal Court until after AEDPA’s effective date.

Accordingly, that application is subject to AEDPA.

Justice O’Connor has filed an opinion concurring in the judgment; Justice Souter has filed a dissenting opinion in which Justices Ginsburg and Breyer join.