HIGH COURT OVERTURNS
RULING SIDESTEPPING REVIEW LIMITS
Mayle v. Felix decision denies murderer’s bid
to attack his conviction in federal court
A United States Supreme Court decision released today
has overturned an earlier ruling by the federal Ninth Circuit Court
of Appeals which allowed a Sacramento murderer to avoid the time limit
for challenging his conviction and sentence in federal court. In 1996,
the Antiterrorism and Effective Death Penalty Act (AEDPA) was signed
into law by President William Clinton. It was adopted by Congress to
restrict the repeated review of state convictions and sentences by the
federal courts on habeas corpus, a process originally intended to give
a person thrown in jail without a trial the chance to appear before
a judge. Among the provisions of the Act is a one-year time limit for
criminal defendants to present claims challenging their convictions
and sentences in federal court. In its ruling, the Ninth Circuit announced
that a defendant can present a new claim after the time limit has expired,
if it is added to an existing petition already before the court and
if the new claim falls into the general category of challenging the
legality of the trial.
The Supreme Court’s 7 to 2 holding rejected that reasoning in
an opinion authored by Justice Ruth Bader Ginsburg which stated, “if
claims asserted after the one-year period could be revived simply because
they relate to the same trial, conviction, or sentence as a timely filed
claim, AEDPA’s limitation period would have slim significance.”
“The threshold established by the Ninth Circuit was so low that
virtually any claim that a defendant might raise would qualify,”
said Charles Hobson, an attorney with the Criminal Justice Legal Foundation.
“Today’s decision makes it clear that when defendants do not
file their claims in a timely manner, and the late claims aren’t
from the same core of facts as a timely claim, these will not be reviewed
on habeas corpus,” he added.
The case of Mayle v. Felix involves the 1995 conviction and
life sentence of Jacoby Felix for the robbery and murder of Richard
Harper. On the night of September 21, 1993, a young couple driving through
a downtown Sacramento, California, neighborhood ran out of gas. Harper,
who was standing near his car, agreed to give the couple a ride to a
gas station. Before the trio could enter Harper’s car, an armed
man with a red rag over his face approached them and ordered them to
“give up the car.” All three fled on foot with the armed man
chasing Harper. Two other armed men with hoods over their faces appeared
near Harper’s car, but the young couple managed to escape. Harper
was not as lucky. He was shot several times while being chased and was
later found in a field with a bullet in the back of his head. After
Harper was killed, the three robbers drove off in his car. The next
morning, police found the car parked near Felix’s house, three
blocks from the murder scene. A witness later testified to hearing Felix
and two accomplices plan the robbery, and to hearing Felix admit that
he believed he had shot Harper. This and other evidence convinced a
jury to convict Felix of robbery and murder and sentence him to life
in prison without the possibility of parole.
After the state Court of Appeal rejected his claims of trial errors
and affirmed his conviction and the state Supreme Court refused to disturb
that holding, Felix raised his claims again on federal habeas corpus
within the one-year time limit required by Congress. After the time
limit for filing claims had expired and while his original petition
was under consideration, his lawyer filed an amended petition which
included a new claim. The District Court rejected the new claim for
violating the time limit. On appeal, the Ninth Circuit overturned the
District Court, announcing that the time limit did not prevent consideration
of the new claim. When the Supreme Court agreed to review that holding,
CJLF joined the case, submitting an amicus curiae (friend of
the court) brief arguing that the Ninth Circuit’s ruling, if allowed
to stand, would obliterate the time limit and its intended purpose to
reduce the unnecessary, time-consuming and expensive federal court review
of state convictions and sentences. The Court’s decision utilized
arguments introduced by the Foundation.
CJLF Associate Attorney Charles Hobson is available
for comment at (916) 446-0345.
The Criminal Justice Legal Foundation has helped win five U. S. Supreme
Court decisions in the Court’s current term. The Foundation’s
brief in this case is available at:
http://www.cjlf.org/briefs/Felix.pdf
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