Sunday, November 3, 2013

Tyler v. Cain case brief

Tyler v. Cain case brief summary
533 U.S. 656 (2001)

Petitioner inmate was convicted of murder and asserted that a jury instruction was improper, based on new case law which found a substantively identical instruction to be unconstitutional. Upon the grant of a writ of certiorari, the inmate appealed the judgment of the United States Court of Appeals for the Fifth Circuit, which affirmed the denial of the inmate's petition for a writ of habeas corpus.

In a prior decision, the United States Supreme Court held that a certain jury instruction was unconstitutional. The inmate then submitted a second petition for a federal writ of habeas corpus, arguing that the similar instruction given in his trial was thus similarly unconstitutional.

  • The Court held, however, that the inmate was not entitled to file the successive habeas petition under the Antiterrorism and Effective Death Penalty Act of 1996, since there was no specific holding by the Supreme Court that the new rule was retroactive to cases on collateral review. 
  • Further, the question of the retroactivity of the new rule was not before the court, since the inmate's second habeas petition required dismissal, regardless of whether the new rule was declared to be retroactive, and any such declaration would thus be merely dictum.


The Court affirmed the judgment of the lower court.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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