Habeas corpus; 28 USC § 2254; The law-of-the-case doctrine & its applicability to a codefendant’s habeas corpus petition; Christianson v. Colt Indus. Operating Corp.; Arizona v. California; Burley v. Gagacki; Pennsylvania v. Finley; Messenger v. Anderson; United States v. Lawrence (5th Cir.); Patterson v. Haskins; Rosales-Garcia v. Holland; Due process implications; Montana v. United States; Taylor v. Sturgell

In this habeas action, the court held that the district court erred by denying petitioner-Edmonds habeas relief based on the law-of-the-case because the doctrine does not apply across separate habeas actions “brought independently by petitioners who were codefendants in the underlying criminal proceedings.” Edmonds brought his habeas petition after his codefendant’s petition was denied. He raised four of the same alleged errors in his petition. The district court dismissed them based on the law of the case because they overlapped with his codefendant’s and the issues had been considered and rejected in that case. The court reversed, noting that “[t]he defining feature of the law-of-the-case doctrine is that it applies only within the same case.” A post-conviction habeas action is a separate civil case, not a subsequent step in the underlying criminal proceedings. Thus, it followed that separate habeas actions filed “by petitioners who were codefendants in the underlying criminal proceedings are separate also—from the criminal proceedings and from each other.” The court concluded that extending the doctrine here would “unmoor” it from its core purposes. Additionally, applying the doctrine across separate habeas “cases would deprive the second petitioner of the opportunity to present his own arguments and would therefore implicate due process concerns.” Edmonds’s four claims at issue must be addressed on the merits. Reversed and remanded.