- Court: United States Supreme Court
- Area(s) of Law: Habeas Corpus
- Date Filed: June 1, 2020
- Case #: 18-6943
- Judge(s)/Court Below: KAGAN, J., delivered the opinion of the Court, in which ROBERTS, C. J., and GINSBURG, BREYER, SOTOMAYOR, GORSUCH, and KAVANAUGH, JJ., joined. ALITO, J., filed a dissenting opinion, in which THOMAS, J., joined.
- Full Text Opinion
Petitioner was convicted of aggravated assault and, after exhausting state remedies, filed suit for federal habeas relief. After the district court denied that relief, Petitioner filed a Rule 59(e) motion which, if granted, would suspend the original judgment's finality for purposes of appeal. That motion was also denied. Because the Fifth Circuit understood Petitioner’s Rule 59(e) motion to be a successive habeas petition, the court dismissed Petitioner’s notice of appeal following the denial of his Rule 59(e) motion as untimely. The Supreme Court holds that a Rule 59(e) motion does not fall within the meaning or a “second or successive habeas application,” violating of the stringent limits under 28 U.S.C. § 2244(b), the gatekeeping provision of the Antiterrorism and Effective Death Penalty Act (AEDPA). The Supreme Court reasoned that “second or successive application” is a term of art and it does not refer to all later-in-time habeas filings. Because Rule 59(e) motions are tied tightly to the underlying judgment in timing and substance, appeals from the habeas judgments are “further iterations of the first habeas application.” The Court pointed to two sources in support of that conclusion: historical habeas doctrine and the purposes of AEDPA—namely, “reducing delay, conserving judicial resources, and promoting finality.” REVERSED AND REMANDED.