Day v. McDonough (formerly Day v. Crosby)
Docket No. 04-1324
Affirmed: The Eleventh Circuit
Argued: February 27, 2006
Decided: April 25, 2006
For Case Analysis: See ABA Preview 261
Did a district court have the power to dismiss on its own initiative a habeas petition as untimely even though the state had (erroneously) conceded in its response that the petition was timely?
Yes. The Court held that the district court in this case had discretion to correct the state's erroneous computation and, accordingly, to dismiss the habeas petition as untimely under the one-year limitation provided by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
From the opinion by Justice Ginsburg (joined by Chief Justice Roberts and by Justices Kennedy, Souter, and Alito):
Ordinarily in civil litigation, a statutory time limitation is forfeited if not raised in a defendant's answer or in an amendment thereto. … And we would count it an abuse of discretion to override a State's deliberate waiver of a limitations defense. In this case, however, the federal court confronted no intelligent waiver on the State's part, only an evident miscalculation of the elapsed time under a statute designed to impose a tight time constraint on federal habeas petitioners. In the circumstances here presented, we hold, the federal court had discretion to correct the State's error and, accordingly, to dismiss the petition as untimely under AEDPA's one-year limitation.
Dissenting: Justice Stevens (joined by Justice Breyer)
Dissenting: Justice Scalia (joined by Justices Thomas and Breyer)
Evans v. Chavis
Docket No. 04-721
Reversed: The Ninth Circuit
Argued: November 9, 2005
Decided: January 10, 2006
For Case Analysis: See ABA Preview 88
Did the Ninth Circuit contravene the Supreme Court's decision in Carey v. Saffold (2002) when it held that a prisoner who delayed more than three years before filing a habeas petition with the California Supreme Court did not "unreasonably" delay filing the petition?
Yes. The Ninth Circuit departed from Saffold's interpretation of the Antiterrorism and Effective Death Penalty Act of 1996 as applied to California's system.
From the opinion by Justice Breyer (joined by Chief Justice Roberts and Justices O'Connor, Scalia, Kennedy, Souter, Thomas, and Ginsburg):
In the absence of (1) clear direction or explanation from the California Supreme Court about the meaning of the term "reasonable time" in the present context, or (2) clear indication that a particular request for appellate review was timely or untimely, the Circuit must itself examine the delay in each case and determine what the state courts would have held in respect to timeliness. That is to say, without using a merits determination as an "absolute bellwether" (as to timeliness), the federal court must decide whether the filing of the request for state-court appellate review (in state collateral review proceedings) was made within what California would consider a "reasonable time." … This is what we believe we asked the Circuit to do in Saffold. This is what we believe it should have done.
Concurring in the judgment: Justice Stevens
Rice et al. v. Collins
Docket No. 04-52
Reversed: The Ninth Circuit
Argued: December 5, 2005
Decided: January 18, 2006
For Case Analysis: See ABA Preview 165
May a federal habeas corpus court reject the presumption of correctness for state fact finding if a rational fact finder could have determined the facts as did the state court?
No. The Ninth Circuit's attempt to use a set of debatable inferences to set aside the state court's conclusion does not satisfy AEDPA's requirements for granting habeas relief.
From the opinion by Justice Kennedy (for a unanimous Court):
Under [the Anti-terrorism and Effective Death Penalty Act] … a federal habeas court must find the state-court conclusion "an unreasonable determination of the facts in light of the evidence presented in the State court proceeding." 28 U. S. C. § 2254(d)(2). Thus, a federal habeas court can only grant Collins' petition if it was unreasonable to credit the prosecutor's race-neutral explanations for the Batson challenge. State-court factual findings, moreover, are presumed correct; the petitioner has the burden of rebutting the presumption by "clear and convincing evidence." § 2254(e)(1). … Although the Ninth Circuit assumed § 2254(e)(1)'s presumption applied in this case … the parties disagree about whether and when it does. We need not address that question. Even assuming, arguendo, that only § 2254(d)(2) applied in this proceeding, the state-court decision was not an unreasonable determination of the facts in light of the evidence presented in the state court.
Concurring: Justice Breyer (joined by Justice Souter)