Lindh v. Murphy

1997-06-23

Headline: New federal habeas rules in the Antiterrorism Act do not apply to noncapital cases pending at enactment, preventing retroactive tightening of relief for prisoners with already-filed federal petitions.

Holding: The Court held that the 1996 amendments to 28 U.S.C. §2254(d) do not apply to noncapital federal habeas petitions that were pending when the Act was enacted, so Lindh’s pending case proceeds under the prior law.

Real World Impact:

Stops AEDPA’s §2254(d) from constraining noncapital habeas cases pending at enactment.
Leaves existing noncapital petitions to proceed under prior habeas standards.
Capital cases may still be subject to chapter 154’s provisions even if pending.

Topics: habeas petitions, retroactive law changes, criminal appeals, death penalty rules

Summary

Background

A Wisconsin man, Aaron Lindh, was tried and convicted of murder and attempted murder after a disputed insanity defense. At trial a psychiatrist’s testimony could not be challenged about a state investigation into the psychiatrist, and Lindh’s Confrontation Clause claim failed on direct appeal. Lindh then filed a federal habeas petition in July 1992. After the federal courts denied relief, Congress passed the Antiterrorism and Effective Death Penalty Act (AEDPA) in April 1996, and the Seventh Circuit later held the new §2254(d) applied to pending cases and denied Lindh relief.

Reasoning

The Court focused on whether AEDPA’s new §2254(d) governs noncapital federal habeas petitions that were already pending when the law took effect. The majority read §107(c), which expressly applied the new capital-case chapter (chapter 154) to pending cases, as implying that the other amendments to the general habeas chapter (chapter 153) were meant only for cases filed after the Act. The Court explained that ordinary rules of construction allowed this negative implication and distinguished purely procedural changes from provisions that affect entitlement to relief. It concluded that §2254(d) does not apply to Lindh’s pending noncapital petition, reversed the Seventh Circuit, and sent the case back for further proceedings consistent with that holding.

Real world impact

Prisoners with noncapital federal habeas petitions already filed when AEDPA became law keep the previous standards for relief. By contrast, chapter 154’s rules for capital cases were explicitly made applicable to pending capital cases in certain circumstances. This ruling is procedural about how the new law is applied and does not resolve the merits of Lindh’s Confrontation Clause claim.

Dissents or concurrances

The dissent argued the Court should have applied traditional retroactivity and jurisdictional principles to reach the opposite result, treating §2254(d) as applicable to pending cases and affirming the court of appeals.