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Tyler v. Cain
United States Supreme Court
533 U.S. 656 (2001)
Melvin Tyler (defendant) was convicted of second-degree murder. The appellate court affirmed. Tyler filed five unsuccessful petitions for post-conviction relief in state court before filing a habeas corpus petition in federal court. The petition was denied. Subsequently, in Cage v. Louisiana, the Supreme Court held a jury instruction nearly identical to the one used in Tyler’s case unconstitutional. Tyler raised this issue in another state petition. The Louisiana State District Court denied the petition, and the Louisiana Supreme Court affirmed. Tyler then requested permission to file another habeas petition under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The United States Court of Appeals for the Fifth Circuit found that Tyler had made a prima facie showing that the claim was based on “a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable” under § 2244(b)(2)(A) and gave Tyler permission to petition for habeas corpus in federal district court. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Thomas, J.)
Concurrence (O’Connor, J.)
Dissent (Breyer, J.)
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