Gonzalez v. Crosby

2005-06-23

Headline: Court allows federal judges to hear certain Rule 60(b) motions that challenge nonmerits habeas rulings, limiting use of those motions to avoid AEDPA’s bar on second or successive petitions.

Holding: The Court held that a Rule 60(b)(6) motion that challenges only a federal court’s nonmerits ruling on the AEDPA statute of limitations is not a successive habeas petition and may be considered by the district court.

Real World Impact:

Lets federal judges decide Rule 60(b) motions that challenge nonmerits habeas rulings without appellate precertification.
Prevents using Rule 60(b) to dodge AEDPA limits on new habeas claims.
Requires "extraordinary circumstances" to reopen final habeas judgments for change-in-law.

Topics: habeas petitions, postconviction relief, federal court procedure, statute of limitations, prisoner rights

Summary

Background

A Florida prisoner serving a 99-year sentence after pleading guilty to robbery with a firearm sought federal review of his conviction, arguing his plea was not knowing and voluntary. The District Court dismissed his habeas petition as time barred because it declined to toll the federal filing deadline while a later state postconviction motion was pending. After this Court later clarified that some state postconviction filings can toll the federal deadline, the prisoner filed a Rule 60(b)(6) motion asking the federal court to reopen the judgment.

Reasoning

The Justices considered whether a Rule 60(b) motion in a habeas case is the same as a new, second habeas petition that AEDPA requires courts of appeals to screen first. They said a Rule 60(b) motion that adds new grounds attacking the conviction or that attacks a prior merits ruling functions like a new habeas petition and must meet AEDPA’s special limits. But a Rule 60(b) motion that challenges only a procedural, nonmerits issue in the earlier federal case—for example, a court’s application of the statute of limitations—does not count as a successive habeas petition and can be resolved by the district court.

Real world impact

Applying those rules to this case, the Court held the prisoner’s motion was a nonmerits challenge and therefore not a successive petition. Still, the Court affirmed denial because reopening under Rule 60(b)(6) requires "extraordinary circumstances," and the change in the law plus the prisoner’s lack of diligence did not meet that high standard.