里弗斯诉格雷罗案

Petitioner Danny Rivers was convicted in Texas state court of continuous sexual abuse of a child and related charges. After unsuccessful direct appeal and state habeas relief, he filed his first federal habeas petition under 28 U.S.C. § 2254 in August 2017. The district court denied the petition in September 2018. While his appeal was pending before the Fifth Circuit, Rivers obtained his trial counsel's client file containing a state investigator's report he believed was exculpatory. The Fifth Circuit denied his request to supplement the record, so Rivers filed a second §2254 petition based on this new evidence. The district court classified it as a "second or successive" application under §2244(b) and transferred it to the Fifth Circuit. The Fifth Circuit affirmed, holding that the first petition's pending appeal did not permit circumvention of successive petition requirements. The Supreme Court granted certiorari on December 6, 2024.

The Supreme Court affirmed the Fifth Circuit's decision in a unanimous opinion delivered by Justice Jackson. The Court held that once a district court enters its judgment with respect to a first-filed habeas petition, a second-in-time filing qualifies as a "second or successive application" properly subject to the requirements of §2244(b). The Court ruled that attempts by state prisoners to raise new claims while their habeas petitions are on appeal amount to "second or successive" petitions generally forbidden under AEDPA.

Whether a habeas petitioner may file a new petition while a current petition is pending on appeal without first receiving authorization from the court of appeals. Specifically, whether a second-in-time filing qualifies as a "second or successive application" under AEDPA once the district court has entered judgment on the first petition, even while appellate review remains pending.

The decision resolved a circuit split on when AEDPA's bar on successive petitions applies. It reinforced strict limits on repeat habeas filings and emphasized finality in criminal cases, making it more difficult for habeas petitioners to introduce new evidence or claims after a district court's final judgment. The ruling potentially limits opportunities for state prisoners to vindicate constitutional rights through habeas corpus when new evidence emerges during appellate review.