McQuiggin v. Perkins
May 28, 2013
Case #: 12–126
Ginsburg, J., delivered the opinion of the Court, in which Kennedy, Breyer, Sotomayor, and Kagan, JJ., joined. Scalia, J., filed a dissenting opinion, in which Roberts, C. J., and Thomas, J., joined, and in which Alito, J., joined as to Parts I, II, and III.
Full Text Opinion: http://www.supremecourt.gov/opinions/12pdf/12-126_lkgn.pdf
Criminal Procedure: A federal habeas petition can overcome the time limits set forth in the Antiterrorism and Effective Death Penalty Act of 1996 if actual innocence is proven.
A jury convicted Respondent of first-degree murder. Subsequently, Respondent filed a federal habeas petition which stated that Respondent had ineffective assistance of trial counsel. Relying on newly discovered evidence, the Respondent attempted to overcome the statute of limitations imposed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The District Court found that Respondent failed to show the appropriate diligence mandated by the AEDPA. The Sixth Circuit reversed finding that Respondent's actual-innocence claim allowed his claim to be considered as if it was timely filed.
The Supreme Court granted certiorari to determine whether a federal habeas petition can overcome the time limits set forth in the AEDPA, if actual-innocence is proven. The Court vacated, remanded and held that proving actual-innocence could overcome a procedural bar. The standard for actual-innocence is that no reasonable juror would have convicted in light of the new evidence. The Court went on to say that unjustifiable delay should not bar claims but should simply be a factor in determining innocence. The Court suggests that this “miscarriage of justice” exception is meant to protect the constitutional rights of a person that may have been falsely convicted.