## Facts

- Melvin Tyler, a Louisiana state prisoner, was convicted of second-degree murder after firing a pistol through a window; ricocheting bullets killed his infant daughter.
- He was sentenced to life imprisonment without parole, and his conviction was affirmed on direct appeal.
- After multiple unsuccessful state postconviction applications and a prior federal habeas petition, Tyler sought additional collateral relief.
- Following Cage v. Louisiana, Tyler filed a new state postconviction petition arguing his jury instructions were substantively identical to those found unconstitutional in Cage; state courts denied relief.
- Tyler sought authorization under AEDPA to file a second or successive federal habeas petition relying on Cage; the federal courts ultimately denied relief, concluding Tyler did not satisfy AEDPA’s retroactivity gatekeeping requirement.

## Issues

1. Whether the rule announced in Cage v. Louisiana had been “made retroactive to cases on collateral review by the Supreme Court” under 28 U.S.C. § 2244(b)(2)(A), permitting a second or successive federal habeas petition.

## Decision

- The Supreme Court affirmed the Fifth Circuit’s judgment denying Tyler’s successive habeas claim.
- The Court held that Cage had not been “made retroactive to cases on collateral review by the Supreme Court” within the meaning of § 2244(b)(2)(A).
- The Court interpreted “made retroactive” to require a Supreme Court holding that a rule applies retroactively on collateral review.
- The Court recognized retroactivity may be shown either by an express retroactivity holding or by multiple Supreme Court holdings that necessarily dictate retroactivity, but found no such holdings regarding Cage.

## Legal Principles

- Under 28 U.S.C. § 2244(b)(2)(A), a second or successive habeas claim based on a new constitutional rule may proceed only if the Supreme Court has made that rule retroactive to cases on collateral review.
- A rule is “made retroactive” only through Supreme Court holdings; lower-court determinations, or lower-court applications of general retroactivity doctrine, do not satisfy the statute.
- Retroactivity can be established by (a) an explicit Supreme Court holding of retroactivity, or (b) multiple Supreme Court holdings that logically permit no other conclusion than retroactivity.

## Conclusion

Tyler v. Cain construes AEDPA’s gatekeeping provision to require that the Supreme Court itself, through its holdings, make a new constitutional rule retroactive before a prisoner may raise that rule in a second or successive federal habeas petition.


Tyler v. Cain, 533 U.S. 656 (2001)