Mayle v. Felix, 545 U.S. 644 (2005)

In the underlying events of *Mayle v. Felix*, Jacoby Lee Felix was convicted in 1995 by a California jury of first-degree murder and second-degree robbery, resulting in a life sentence. Following his conviction, Felix filed a pro se federal habeas corpus petition within the one-year limitation period established by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). In his initial petition, he raised several claims, including a violation of his Sixth Amendment rights due to the admission of a witness's videotaped testimony. After the expiration of the AEDPA time limit, Felix, with the assistance of appointed counsel, filed an amended petition eight months later, introducing a new claim that his Fifth Amendment rights were violated when police used coercive tactics during pretrial interrogation, leading to the admission of damaging statements at trial. The procedural history of the case involves the Ninth Circuit Court of Appeals, which ruled that Felix's amended petition related back to the original filing date, thus allowing the new claim to be considered timely. This decision prompted the warden, Deneice A. Mayle, to seek a writ of certiorari from the Supreme Court to resolve the issue of whether the amended petition could relate back under Federal Rule of Civil Procedure 15(c)(2) despite the new claim arising after the AEDPA deadline. The relevant background context includes the legal framework established by AEDPA, which imposes a strict one-year statute of limitations for federal habeas corpus petitions, and the procedural rules governing amendments to pleadings in civil cases. The case highlights a significant point of contention in federal appellate courts regarding the timeliness of amended habeas petitions, particularly when new claims are introduced that differ from the original claims in both time and type. The Supreme Court ultimately addressed the question of whether Felix's amended petition could relate back to his original filing, which was crucial for determining the viability of his Fifth Amendment claim.

Whether an amended habeas petition filed after the one-year limitation period imposed by the Antiterrorism and Effective Death Penalty Act relates back to the date of the original petition when the amended claim is based on different facts and a new ground for relief.

The judgment is reversed.