Gonzalez v. Crosby, Secretary, Florida Department of Corrections
545 U.S. 524 (2005)
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Rule of Law:
A motion under Federal Rule of Civil Procedure 60(b) is not a 'second or successive' habeas corpus petition if it challenges a procedural defect in the prior federal habeas proceeding rather than attacking the substance of the federal court's resolution of a claim on the merits. However, to obtain relief under Rule 60(b)(6), the movant must demonstrate 'extraordinary circumstances,' which a subsequent change in decisional law typically does not constitute.
Facts:
- Aurelio Gonzalez pleaded guilty in a Florida state court to one count of robbery with a firearm.
- He was sentenced to a 99-year prison term, which he began serving in 1982.
- Approximately 12 years later, Gonzalez began to seek relief from his conviction.
- Gonzalez filed two separate motions for postconviction relief in Florida state courts, both of which were denied.
Procedural Posture:
- Aurelio Gonzalez filed a federal habeas corpus petition in the U.S. District Court for the Southern District of Florida.
- The District Court dismissed the petition as time-barred under AEDPA's statute of limitations.
- A judge of the U.S. Court of Appeals for the Eleventh Circuit denied Gonzalez a certificate of appealability (COA).
- The U.S. Supreme Court subsequently held in Artuz v. Bennett that a state postconviction motion could toll AEDPA's statute of limitations even if it was procedurally barred.
- Nine months after the Artuz decision, Gonzalez filed a motion for relief from judgment under Federal Rule of Civil Procedure 60(b)(6) in the District Court, arguing the prior dismissal was incorrect under Artuz.
- The District Court denied the Rule 60(b) motion.
- The U.S. Court of Appeals for the Eleventh Circuit, sitting en banc, affirmed the denial, holding that the motion was functionally a 'second or successive' habeas petition and was therefore barred without prior authorization.
- The U.S. Supreme Court granted certiorari to resolve the issue.
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Issue:
Does a Federal Rule of Civil Procedure 60(b) motion, filed by a habeas petitioner to challenge the district court's previous dismissal of their petition on statute-of-limitations grounds, constitute a 'second or successive' habeas corpus petition subject to the restrictions of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA)?
Opinions:
Majority - Justice Scalia
No. A Rule 60(b) motion that attacks a defect in the integrity of the federal habeas proceedings, rather than the merits of the underlying state conviction, is not a 'second or successive' habeas petition under AEDPA. The court reasoned that AEDPA's restrictions on successive petitions apply to filings containing a 'claim,' which is an asserted federal basis for relief from the state court conviction. A Rule 60(b) motion presents a 'claim' if it adds a new ground for relief or attacks the federal court's prior resolution of a claim on the merits. However, a motion is not a successive petition if it attacks a procedural ruling that precluded a merits determination, such as a dismissal on statute-of-limitations grounds. Gonzalez's motion challenged only the district court's procedural ruling and was therefore a true Rule 60(b) motion. Despite this, the Court affirmed the denial of his motion, holding that relief under Rule 60(b)(6) requires 'extraordinary circumstances,' and a subsequent change in decisional law, such as the Supreme Court's ruling in Artuz v. Bennett, does not qualify as such. Gonzalez's lack of diligence in appealing the original statute-of-limitations ruling further undermined his claim of extraordinary circumstances.
Dissenting - Justice Stevens
The dissent agreed with the majority that Gonzalez's Rule 60(b) motion was not a successive habeas petition. However, it strongly disagreed with the Court's decision to adjudicate the merits of the Rule 60(b) motion. The proper course would have been to remand the case to the District Court to determine in the first instance whether 'extraordinary circumstances' existed. The dissent argued that Rule 60(b) decisions are equitable and fact-intensive, making them ill-suited for initial determination by an appellate court. The dissent also contended that the majority understated the significance of a petitioner being wrongly shut out of federal court by a clear procedural error, and that a supervening change in procedural law, combined with diligence and a colorable underlying claim, could constitute extraordinary circumstances.
Concurring - Justice Breyer
The concurrence joined the majority opinion but wrote separately to emphasize its agreement with the standard that a true Rule 60(b) motion is one that 'attacks, not the substance of the federal court’s resolution of a claim on the merits, but some defect in the integrity of the federal habeas proceedings.' The concurrence expressed concern that other language in the majority's opinion, particularly the discussion of the word 'claim,' might be misinterpreted to imply a different, less appropriate standard.
Analysis:
This decision clarifies the critical distinction between a true motion for relief from judgment under Rule 60(b) and a disguised successive habeas petition governed by AEDPA's strict limitations. It provides a narrow path for petitioners to correct certain procedural errors in their initial habeas proceedings, such as an erroneous statute-of-limitations dismissal, without needing pre-authorization from a court of appeals. However, the Court simultaneously reinforced the principle of finality by setting a very high bar for success on such motions, holding that a mere change in decisional law does not constitute the 'extraordinary circumstances' required for relief under Rule 60(b)(6). The ruling thus preserves finality while creating a procedural exception that is difficult to successfully invoke.
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