Mayle v. Felix
In 1995, Felix was convicted of first degree murder and second degree robbery in California state court. On appeal, he argued that the admission into evidence of videotaped statements of a key prosecution witness violated his Sixth Amendment right to confront the witnesses against him. The Court of Appeal affirmed the judgment. The California Supreme Court denied Felix’s Petition for Review and his state conviction became final on August 12, 1997.
On May 8, 1998, Felix filed in federal district court a pro se petition for writ of habeas corpus raising the same arguments that were raised in his state appeal. The one-year statute of limitations for habeas relief expired on August 11, 1998. On January 28, 1999, Felix filed, through counsel, an amended petition that included the Confrontation Clause claim asserted in the original petition and an additional claim, which alleged that the state court violated his rights to due process and against self-incrimination by admitting into evidence allegedly involuntary statements that Felix had made during a police interview. Federal Rule of Civil Procedure 15(c)(2), provides that an amendment "relates back" to the date of the original pleading when “the claim or defense asserted in the amended pleading arose out of the conduct, transaction, or occurrence set forth . . . in the original pleading.” The district court found that the coerced confession claim did not relate back to the Confrontation Clause claim because it did not arise from the “same core of facts.” Accordingly, the coerced confession claim was barred by the one-year statute of limitation.
On appeal, the Ninth Circuit Court of Appeals reversed the ruling of the district court. It held that Felix's amended claim arose out of the same transaction or occurrence as his original petition because the transaction or occurrence at issue is his state trial and conviction. Thus, the amended claim relates back to the original petition under Rule 15(c)(2).
Question Presented:
When a habeas petitioner challenging a state judgment amends his petition to include a new claim, does the amendment relate back to the date of the filing
of his petition and thus avoid the one-year statute of limitations, 28 U.S.C. ยง 2244(d)(1), so long as the new claim stems from the prisoner's trial, conviction, or sentence?
