Gonzalez v. Crosby
In 1992, Gonzalez pled guilty to armed robbery in a Florida state court and was sentenced to 99 years in prison. Gonzalez did not directly appeal his conviction or sentence. In 1996, he filed a state habeas petition attacking his conviction on the basis of newly discovered evidence that showed his plea was unintelligent, unknowing, and involuntary. After the state courts denied his petition, he filed in 1998 a federal habeas petition asserting the same claim, which the district court denied as time barred because it was not filed within the one-year statute of limitations. In 2000, the Supreme Court interpreted the meaning of the statutory limit on federal habeas petitions in Artuz v. Bennet. Based on this case, Gonzalez filed a motion under Rule 60(b) of the federal rules of civil procedure, asking the district court to vacate its previous ruling in light of Artuz. The district court denied his motion but the Eleventh Circuit Court of Appeals granted a certificate of appealability. The en banc Court of Appeals then held that Gonzalez's Rule 60(b) motion was barred by AEDPA, which specifically restricts the filing of second or successive petitions for post-conviction relief. The court reasoned that the restrictions in AEDPA "trumped" Rule 60(b) because AEDPA applies specifically to habeas petitions and was enacted after Rule 60(b).
Question Presented:
Whether the court of appeals erred in holding that every Rule 60(b) motion (other than for fraud under (b)(3)) constitutes a prohibited "second or
successive" petition as a matter of law, in square conflict with decisions of this Court and of other circuits.
