Felker v. Turpin
518 U.S. 651 (1996)
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Rule of Law:
The Antiterrorism and Effective Death Penalty Act's (AEDPA) provisions restricting successive habeas corpus petitions and limiting appellate review of gatekeeping decisions do not violate the Constitution's Exceptions Clause or Suspension Clause because they do not eliminate the Supreme Court's authority to entertain original habeas petitions.
Facts:
- In 1976, Ellis Wayne Felker used deceptions to lure Jane W. to his home, where he forcibly raped and sodomized her.
- Jane W. escaped when Felker fell asleep and notified the police.
- Felker was convicted of aggravated sodomy for the attack on Jane W. and was sentenced to 12 years in prison.
- After being paroled four years later, Felker met Joy Ludlam on November 23, 1981.
- Felker used a deceptive job offer to induce Ludlam to visit him the next day.
- Ludlam was last seen alive on the evening of November 24, 1981, and her body was discovered two weeks later in a creek.
- A forensic analysis determined that Ludlam had been beaten, raped, sodomized, and strangled to death.
- Investigators discovered forensic evidence, including hair and clothing fibers, that linked Felker to Ludlam's murder.
Procedural Posture:
- A Georgia state jury convicted Ellis Wayne Felker of murder and other crimes and sentenced him to death.
- The Georgia Supreme Court affirmed the conviction and sentence, and the U.S. Supreme Court denied certiorari.
- Felker's state petition for collateral relief was denied by a state trial court, and the Georgia Supreme Court declined to issue a certificate of probable cause for appeal.
- Felker then filed his first petition for a writ of habeas corpus in the U.S. District Court for the Middle District of Georgia, which the court denied.
- The U.S. Court of Appeals for the Eleventh Circuit affirmed the district court's denial.
- After the President signed AEDPA into law, Felker filed a motion in the Eleventh Circuit for leave to file a second successive federal habeas corpus petition.
- The Eleventh Circuit denied the motion, concluding his claims did not meet the new standards set by AEDPA.
- Felker then filed a petition in the U.S. Supreme Court seeking both a writ of habeas corpus and a writ of certiorari to review the Eleventh Circuit's decision.
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Issue:
Do the provisions of the Antiterrorism and Effective Death Penalty Act of 1996 that limit a state prisoner's ability to file a second or successive habeas corpus petition, and that bar Supreme Court review of a court of appeals' denial of authorization to file such a petition, violate Article III, § 2 (the Exceptions Clause) or Article I, § 9 (the Suspension Clause) of the Constitution?
Opinions:
Majority - Chief Justice Rehnquist
No. The provisions of the Antiterrorism and Effective Death Penalty Act of 1996 do not violate the Exceptions Clause or the Suspension Clause. While AEDPA's § 2244(b)(3)(E) removes the Supreme Court's authority to review a court of appeals' 'gatekeeping' decision via appeal or certiorari, it does not repeal the Court's separate, pre-existing authority to entertain original petitions for a writ of habeas corpus under 28 U.S.C. § 2241. Citing Ex parte Yerger, the Court reasoned that repeals of jurisdiction by implication are disfavored, and since this alternative avenue for review exists, the Act does not unconstitutionally strip the Court of its jurisdiction under the Exceptions Clause. Furthermore, the new restrictions on successive petitions do not amount to a 'suspension' of the writ under the Suspension Clause; rather, they are a permissible modification of the 'abuse of the writ' doctrine, which Congress has the power to regulate.
Concurring - Justice Stevens
No. The Court's opinion correctly concludes the Act is constitutional, but its reasoning is incomplete. The Act does not purport to limit the Supreme Court's jurisdiction under the All Writs Act or its ability to review appropriate interlocutory orders from the courts of appeals. These alternative statutory avenues for review, in addition to the Court's original habeas jurisdiction, provide further reason to reject the petitioner's argument that the Act violates Article III. By considering earlier gatekeeping orders while exercising its own habeas jurisdiction, the Court can provide the 'functional equivalent of direct review.'
Concurring - Justice Souter
No. The statute is not unconstitutional on its face or as applied in this case because the petitioner's claims would fail even under pre-Act standards. However, if it later becomes clear that all other statutory avenues for reviewing a 'gatekeeping' determination are closed, and if the courts of appeals adopt divergent interpretations of the gatekeeping standard, the question of whether the statute exceeds Congress's power under the Exceptions Clause would be open for future consideration. The opinion serves as a warning that the constitutionality of the Act could be challenged in the future under different circumstances.
Analysis:
This decision solidified the constitutionality of the Antiterrorism and Effective Death Penalty Act (AEDPA), a landmark piece of legislation that dramatically curtailed federal habeas corpus relief for state prisoners. By upholding the 'gatekeeping' mechanism for successive petitions, the Court prioritized principles of finality and comity over broad access to federal review. While the Court preserved its own authority to hear original habeas petitions as a constitutional safety valve, it signaled that this power would be exercised only in 'exceptional circumstances,' effectively affirming Congress's power to impose strict procedural limits on the Great Writ. The ruling has had a profound impact, making it exceedingly difficult for prisoners to raise new claims in federal court after their first habeas petition has been adjudicated.
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