Paul Goodwin v. Troy Steele
814 F.3d 901
8th Cir.2014Background
- Paul Goodwin, sentenced to death in Missouri, previously litigated intellectual-disability claims in state and federal habeas proceedings and received adverse rulings.
- Missouri courts relied on multiple IQ tests (scores mainly above 70; one score of 72) and treated a single score within the Wechsler five‑point margin as insufficient to raise a triable issue.
- Goodwin filed a supplemental § 2254 petition after the U.S. Supreme Court decided Hall v. Florida, arguing Hall required Missouri to consider adaptive‑functioning evidence despite his scores.
- The district court dismissed the supplemental petition as a second or successive application barred by 28 U.S.C. § 2244(b)(1) and, alternatively, denied it on the merits; it declined to grant a COA.
- Goodwin sought a certificate of appealability and authorization from the Eighth Circuit to file a second/successive petition; he also moved for stays of execution.
- The Eighth Circuit majority denied a COA, denied authorization to file a second or successive petition (finding no prima facie showing of Hall’s retroactivity), and denied stay motions; Judge Murphy concurred in part and dissented in part, arguing Hall should be treated as retroactive and authorization granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Goodwin’s Hall‑based claim is barred as second or successive under § 2244(b)(1) | Goodwin contends Hall supplies a new basis distinct from his Atkins claim; thus not the same claim previously presented | State says Goodwin already raised an intellectual‑disability/Atkins claim in his prior habeas petition, so § 2244(b)(1) requires dismissal | Held: Claim is barred under § 2244(b)(1); reasonable jurists would not debate this conclusion (per Thompson v. Nixon) |
| Whether Goodwin needed prior authorization from the court of appeals before filing the supplemental petition | Goodwin sought to present Hall grounds without prior authorization, arguing ripeness and novelty | State contends § 2244(b)(3)(A) required Goodwin to move in the appellate court first | Held: Goodwin failed to seek required authorization; dismissal is correct |
| Whether Hall constitutes a new rule of constitutional law made retroactive under § 2244(b)(2)(A) (prima facie showing) | Goodwin (and concurrence) argue Hall announces a substantive rule expanding the protected class (those who may be intellectually disabled) and should be treated as retroactive | Majority argues Hall announced procedural safeguards (allowing presentation of adaptive‑functioning evidence) and the Supreme Court has not held Hall retroactive; under Tyler v. Cain retroactivity requires Supreme Court holding | Held: No prima facie showing of retroactivity; authorization denied (majority). Concurrence would find Hall retroactive and would authorize filing |
| Whether Goodwin’s Hall claim was not ripe until Hall was decided (timing/ripeness) | Goodwin analogizes to Ford incompetency ripeness cases (Stewart, Panetti) to argue claim ripened only after Hall | State and majority argue Eighth Amendment intellectual‑disability claim ripened earlier; those cases differ factually | Held: Claim was ripe before Hall; Stewart/Panetti/Magwood do not make Goodwin’s claim unripe |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (2002) (Eighth Amendment prohibits execution of intellectually disabled persons)
- Hall v. Florida, 134 S. Ct. 1986 (2014) (IQ within test margin of error requires opportunity to present adaptive‑functioning evidence)
- Tyler v. Cain, 533 U.S. 656 (2001) (for § 2244(b)(2)(A) retroactivity, Supreme Court must have held a new rule retroactive)
- Thompson v. Nixon, 272 F.3d 1098 (8th Cir. 2001) (a new argument based on intervening decisional law does not avoid § 2244(b)(1) bar)
- In re Henry, 757 F.3d 1151 (11th Cir. 2014) (denying authorization; Hall not shown to be retroactive)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (distinguishing substantive rules that alter the class of persons the law punishes)
- Penry v. Lynaugh, 492 U.S. 302 (1989) (noting substantive rules that prohibit execution regardless of procedures would be retroactive)
- Stewart v. Martinez‑Villareal, 523 U.S. 637 (1998) (Ford‑competency claims may ripen only after execution date)
- Panetti v. Quarterman, 551 U.S. 930 (2007) (similar competency ripeness holding)
- Magwood v. Patterson, 561 U.S. 320 (2010) (ripeness and successive‑petition principles explained)