McQuiggin v. Perkins (2012)
- Docket
- 12-126
- Decided
- 2012-01-01
Summary
Question: 1. Must an accused claiming actual innocence prove that extraordinary circumstances prevented the timely filing of his habeas petition? 2. If so, must an accused pursue an actual innocence claim with the same reasonable diligence required to toll the statute of limitations for other habeas petition claims? Conclusion: No, yes. Justice Ruth Bader Ginsburg delivered the opinion of the 5-4 majority. The Court held that a credible showing of actual innocence allows a petitioner to pursue habeas corpus relief on the merits of the case regardless of any procedural bar, such as a statute of limitations. The miscarriage of justice exception that allows petitioners to pursue cases that would otherwise be dismissed as untimely demonstrates clear congressional intent to allow petitioners arguing actual innocence to do the same. The Court also held that, to prove the actual innocence claim, the petitioner must prove that it is more likely than not that a reasonable juror would not convict in light of the new evidence. Under this burden of proof, unexplained delay may impact the petitioner's credibility but does not necessarily defeat the claim. Justice Antonin Scalia wrote a dissenting opinion in which he argued that Congress enacted a valid barrier to habeas corpus relief, and the majority's opinion does not have the authority to overrule Congress. He argued that the Supreme Court does not have the legislative power to create an exception where one does not exist. Chief Justice John G. Roberts, Jr., Justice Clarence Thomas, and Justice Samuel A. Alito, Jr. joined in the dissent.