Woodford v. Garceau
Garceau was convicted of a double homicide in California state court and sentenced to death. The California Supreme Court affirmed his conviction and sentence and denied his state habeas petition on the merits. Garceau filed a habeas petition in federal district court, raising 28 separate grounds for relief, and moved for an evidentiary hearing on several of his claims. The district court denied his motion for an evidentiary hearing and later denied his petition. The court of appeals reversed, holding that habeas relief was warranted because the ”other crimes” jury instruction, which allowed the jury to draw an inference of criminal propensity from other crimes evidence, violated the Due Process clause and was not harmless. It also held that, although Garceau's petition for the writ of habeas corpus was filed after the effective date of the Antiterrorism and Effective Death Penalty Act (AEDPA), the AEDPA did not apply to his petition because it was already ”pending” as of the effective date of the statute. The court held that Garceau’s petition was pending as of May 12, 1995, the date he requested both that federal habeas counsel be appointed and that his execution be stayed
Question Presented:
Do the provisions of the AEDPA apply to capital cases so long as the federal petition is filed on or after the AEDPA's effective date?
