Woodford v. Garceau, 538 U.S. 202 (2003)

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certiorari to the united states court of appeals for the ninth circuit

No. 01-1862. Argued January 21, 2003—Decided March 25, 2003

Amendments made to 28 U. S. C., ch. 153, by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) do not apply to cases pending in federal court on April 24, 1996—AEDPA's effective date. Lindh v. Murphy, 521 U. S. 320. Respondent was convicted of first-degree murder and sentenced to death in California state court. After his petition for state postconviction relief was denied, he moved for the appointment of federal habeas counsel and a stay of execution in Federal District Court on May 12, 1995, and later filed a federal habeas application on July 2, 1996. Although he filed the habeas application after AEDPA's effective date, the District Court concluded, inter alia, that it was not subject to AEDPA because his motions for counsel and a stay were filed prior to that date. The Ninth Circuit agreed that the application was not subject to AEDPA, but reversed for reasons not relevant here.

Held: For purposes of applying the Lindh rule, a case does not become

"pending" until an actual application for habeas relief is filed in federal court. Respondent's application is subject to AEDPA's amendments because it was not filed until after AEDPA's effective date. Pp. 205-210.

(a) Because of AEDPA's heavy emphasis on the standards governing the review of a habeas application's merits, the Court interprets the Lindh rule in view of that emphasis. Thus, whether AEDPA applies to a state prisoner turns on what was before a federal court on AEDPA's effective date. If, on that date, the state prisoner had before a federal court a habeas application seeking an adjudication on the merits of the prisoner's claims, then AEDPA does not apply. Otherwise, an application filed after AEDPA's effective date should be reviewed under AEDPA, even if other filings by that same applicant—e. g., a request for the appointment of counsel or a motion for a stay of execution—were presented to a federal court prior to AEDPA's effective date. A review of the amended chapter 153 supports this conclusion. For example, 28 U. S. C. 2254(e)(1) provides that, "[i]n a proceeding instituted by an application for a writ of habeas corpus by a person in custody pursuant to the judgment of a State court, a determination of a factual issue made by a State court shall be presumed to be correct." (Emphasis added.)

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