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Thursday, June 23, 2005

Gonzalez: Rule 60(b) applies to habeas

In Gonzalez v. Crosby, 2005 WL 1469516 (June 23, 2005), the Supreme Court (7-2) held that a habeas petitioner can bring a motion under Fed. R. Civ. P. 60(b) which challenges not the substance of a federal court’s prior resolution of a habeas petition on the merits, but "some defect in the integrity of the federal habeas proceedings." The Court rejected the Eleventh Circuit’s blanket rule that all Rule 60(b) motions were prohibited because of their inconsistency with the policies of AEDPA.
The Court noted that AEDPA merely limited "applications" for habeas relief, and held that a "claim" in a Rule 60(b) motion would not necessarily qualify as an "application" for habeas relief. The Court stated that Rule 60(b) "has an unquestionably valid role to play in habeas cases," pointing out that it can enable parties to obtain relief from habeas judgments which were mistakenly entered. The Court further noted that potential friction between AEDPA and Rule 60(b) was limited by the "extraordinary circumstances" required to obtain Rule 60(b) relief.
The Court found that Gonzalez had failed to show "extraordinary circumstances" because his only basis for reopening the judgment was that the statute of limitations ground for denying him habeas relief was incorrect in light of a subsequent Supreme Court interpretation of this limitations provision. The Court explained that changes in law do not always provide a basis for reopening cases long final. The Court further faulted the petitioner for his lack of diligence in seeking appellate review of the adverse limitations ruling. Decision here.