Felker v. Turpin

1996-06-28

Headline: New federal law narrows second habeas petitions but the Court allows original Supreme Court habeas petitions to proceed, limiting review of appeals‑court gatekeeping and tightening standards for death‑penalty relief.

Holding: The Act does not stop the Supreme Court from hearing original habeas petitions, but it narrows standards for relief and bars certiorari of appeals‑court gatekeeping denials.

Real World Impact:

Makes second or successive federal habeas petitions harder to bring.
Prevents certiorari review of appeals courts’ gatekeeping decisions on second petitions.
Leaves only narrow original‑petition access directly to the Supreme Court.

Topics: habeas corpus, death penalty appeals, federal court procedures, limits on appeals

Summary

Background

The case involves a Georgia man sentenced to death for the 1981 murder of Joy Ludlam and earlier sexual offenses against another woman. After state courts and federal district and appeals courts denied his challenges, he sought a second round of federal habeas relief soon after Congress enacted the Antiterrorism and Effective Death Penalty Act (the Act). The Eleventh Circuit denied his motion to file a second petition and he asked the Supreme Court for both an original habeas writ and review of the court of appeals’ gatekeeping decision.

Reasoning

The Court considered whether the Act prevents the Supreme Court from hearing original habeas petitions and whether the Act suspends the writ or unconstitutionally limits the Court’s appellate power. The Justices held that the Act changes the standards for granting relief and bars review by appeal or certiorari of appeals‑court orders authorizing second petitions, but it does not repeal the Court’s power to hear original habeas petitions. The Court further concluded the Act’s limits on successive petitions do not amount to an unconstitutional suspension of the writ.

Real world impact

The decision means people on state death rows or others seeking second federal habeas petitions face a stricter statutory gate. The Supreme Court kept open a narrow path for original petitions, but review of appeals‑court “gatekeeper” denials by certiorari or direct appeal is foreclosed. In this specific case, the Court denied the requested habeas relief.

Dissents or concurrances

Several Justices concurred to explain limits on the decision. They agreed with the result but noted remaining questions about other possible routes for Supreme Court review and emphasized statutory and constitutional nuances.