The U.S. Supreme Court has unanimously ruled that new claims cannot be added to a habeas corpus petition after a final judgment, aligning with strictures established by federal legislation such as the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). This ruling impacts Danny Richard Rivers, convicted of child sexual abuse in Texas, who sought to introduce potentially exculpatory evidence while his appeal was pending. Justice Ketanji Brown Jackson, writing for the majority in Rivers v. Guerrero, emphasized the importance of finality in criminal cases to avoid prolonged litigation. The court upheld that any filing after the district court’s final judgment is deemed “second or successive” under AEDPA.
This decision underscores a circuit split over when AEDPA’s bar on successive petitions applies, with the Second Circuit allowing new claims until appellate reviews conclude, in contrast to others like the Fifth Circuit, which restrict amendments post district court judgment. The ruling follows expressions of skepticism by the justices on permitting the amendment of habeas petitions during appeals, which might undermine AEDPA’s procedural gatekeeping.
The case number for this matter is 23-1345 in the Supreme Court of the United States.