Tyler v. Cain
United States Supreme Court
533 U.S. 656 (2001)
After Melvin Tyler's (defendant) multiple state post-conviction petitions and an initial federal habeas petition were denied, the Supreme Court in a separate case (Cage v. Louisiana) held a jury instruction nearly identical to the one used at Tyler's trial unconstitutional; Tyler sought permission for a successive habeas petition raising this claim, and the Fifth Circuit found he'd made a prima facie showing the claim rested on a new constitutional rule 'made retroactive... by the Supreme Court' under AEDPA Section 2244(b)(2)(A), granting permission to petition. The Supreme Court granted certiorari.
Whether, under AEDPA Section 2244(b)(2)(A), the Supreme Court must hold that a new rule applies retroactively in order for an inmate to file a successive habeas corpus petition on that ground.