Gonzalez v. Crosby, 545 U.S. 524 (2005)
Primary Holding
A motion for relief from a judgment in a habeas corpus case, filed under Federal Rule of Civil Procedure 60(b), is subject to the restrictions that apply to “second or successive” habeas corpus petitions under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
In the case of Gonzalez v. Crosby, the Supreme Court decided that if someone wants to challenge a court's decision about their imprisonment, they need to follow strict rules if they’ve already tried to do this before. This matters because it sets clear limits on how many times a person can ask for a second chance in court after a conviction, which can affect their ability to seek justice. For consumers, this case reinforces the idea that there are specific legal procedures that must be followed when trying to overturn a conviction, protecting the integrity of the legal system. If someone is in a similar situation and has already made a previous attempt to challenge their conviction, they need to be aware that they may face additional hurdles in court.
AI-generated plain-language summary to help you understand this case
In Gonzalez v. Crosby, 545 U.S. 524 (2005), petitioner Aurelio O. Gonzalez pleaded guilty to robbery with a firearm in a Florida Circuit Court in 1982, receiving a 99-year sentence. He did not appeal his conviction initially but sought postconviction relief approximately 12 years later, filing two motions in state court, both of which were denied. In June 1997, Gonzalez filed a federal habeas corpus petition in the United States District Court for the Southern District of Florida, claiming that his guilty plea was not made knowingly and voluntarily. However, the District Court dismissed his petition as time-barred under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), concluding that his filing was late by two months due to the statute of limitations. Following the dismissal of his habeas petition, Gonzalez filed a "Motion to Amend or Alter Judgment" in November 2000, arguing that the District Court's time-bar ruling was incorrect based on the Supreme Court's decision in Artuz v. Bennett, which clarified the definition of "properly filed" applications for state postconviction relief. He invoked Federal Rule of Civil Procedure 60(b)(6) to seek relief from the final judgment. The District Court denied this motion, leading Gonzalez to appeal the decision. The Eleventh Circuit initially granted a certificate of appealability (COA), but later quashed it as improvidently granted. After rehearing the case en banc, the court ultimately upheld the District Court's denial of Gonzalez's Rule 60(b) motion, stating that such motions were effectively treated as "second or successive" habeas petitions under AEDPA. The case raised significant questions about the interpretation of AEDPA's restrictions on successive habeas petitions and the applicability of Rule 60(b) motions in the context of federal habeas corpus proceedings. The Supreme Court's review focused on whether Gonzalez's motion for relief from judgment was subject to the same limitations as a second or successive habeas petition, which would require him to meet stringent criteria to proceed.
Whether, in a habeas case, motions for relief from judgment under Federal Rule of Civil Procedure 60(b) are subject to the additional restrictions that apply to “second or successive” habeas corpus petitions under the provisions of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- April 25, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Scalia
- Damages Awarded
- N/A
- Data Quality
- high
Mayle v. Felix, 545 U.S. 644 (2005)
Consumer LostAn amended habeas petition does not relate back to the date of the original petition under Federal Rule of Civil Procedure 15(c)(2) when it asserts a new ground for relief that is supported by facts differing in both time and type from those in the original pleading, thereby not escaping the one-year limitation period imposed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
Pace v. DiGuglielmo, 544 U.S. 408 (2005)
Consumer LostA state postconviction petition rejected by the state court as untimely is not considered "properly filed" under the federal Antiterrorism and Effective Death Penalty Act's tolling provision, and therefore does not toll the one-year statute of limitations for filing a federal habeas corpus petition.
Eberhart v. United States, 546 U.S. 12 (2005)
Consumer WonFederal Rule of Criminal Procedure 33's deadline for filing motions for a new trial is a claim-processing rule rather than a jurisdictional one, meaning that noncompliance with the deadline can be waived and is not a bar to the district court's ability to consider the motion.
Johnson v. United States, 544 U.S. 295 (2005)
Consumer LostThe period for the 1-year statute of limitations under 28 U.S.C. §2255 begins when a petitioner receives notice of the order vacating a prior conviction used to enhance their federal sentence, provided that the petitioner has pursued the vacatur with due diligence in state court.