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Danny Richard Rivers v. Eric Guerrero, Director, Texas Department of Criminal Justice, Correctional Institutions Division

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 21-11031 · judgment April 15, 2024


Decided · June 12, 2025
Pre-decision estimate: 5% cert probability (95% interval 3%–8%)

Before the decision, modestly above the 4.1% base rate. The model weighted this up for a Fifth Circuit decision below, a petition filed soon after the judgment below, and a circuit split argued in the petition, and down for a state or local-government respondent.

Question presented

Under the federal habeas statute, a prisoner "always gets one chance to bring a federal habeas challenge to his conviction," Banister v. Davis, 590 U.S. 504, 509 (2020). After that, the stringent gatekeeping requirements of 28 U.S.C. § 2244(b)(2) bar nearly all attempts to file a "second or successive habeas corpus application." Here, petitioner sought to amend his initial habeas application while it was pending on appeal. The Fifth Circuit applied § 2244(b)(2) and rejected the amended filing. The circuits are intractably split on whether § 2244(b)(2) applies to such filings. The Fifth, Sixth, Seventh, Eighth, Ninth, and Eleventh Circuits hold that § 2244(b)(2) categorically applies to all second-in-time habeas filings made after the district court enters final judgment. The Second Circuit disagrees, applying § 2244(b)(2) only after a petitioner exhausts appellate review of his initial petition. And the Third and Tenth Circuits exempt some second-in-time filings from § 2244(b)(2), depending on whether a prisoner prevails on his initial appeal (Third Circuit) or satisfies a seven-factor test (Tenth Circuit). The question presented is: Whether § 2244(b)(2) applies (i) only to habeas filings made after a prisoner has exhausted appellate review of his first petition, (ii) to all second-in-time habeas filings after final judgment, or (iii) to some second-in-time filings, depending on a prisoner's success on appeal or ability to satisfy a seven-factor test.

Counsel of record

For petitioner
Peter Andrew Bruland
Sidley Austin LLP

For respondent
Aaron Lloyd Nielson
Office of the Texas Attorney General

Case

Conference history
Distributed for 4 conferences

Amicus briefs
3 cert-stage · 10 merits
(5 supporting pet./neither, 5 respondent)

Argument & decision

Argued March 31, 2025 — Peter A. Bruland · Aaron L. Nielson. Audio and transcript

Decided June 12, 2025. Opinion by Jackson.

Proceedings

  1. Jul 14 2025
    Judgment Issued.
  2. Jun 12 2025
    Adjudged to be AFFIRMED. Jackson, J., delivered the opinion for a unanimous Court.
  3. Mar 31 2025
    Argued. For petitioner: Peter A. Bruland, Washington, D. C. For respondent: Aaron L. Nielson, Solicitor General, Austin, Tex.; and Matthew Guarnieri, Assistant to the Solicitor General, Department of Justice, Washington, D. C. (for United States, as amicus curiae.)
  4. Mar 20 2025
    Reply of petitioner Danny Richard Rivers filed. (Distributed)
  5. Mar 10 2025
    Motion of the Acting Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument GRANTED.
  6. Feb 27 2025
    Brief amicus curiae of United States filed. (Distributed)
  7. Feb 27 2025
    Brief amicus curiae of Senator John Cornyn filed. (Distributed)
  8. Feb 27 2025
    Brief amici curiae of Arkansas, et al. filed. (Distributed)
  9. Feb 27 2025
    Brief amici curiae of Pennsylvania, et al. filed. (Distributed)
  10. Feb 27 2025
    Brief amicus curiae of Criminal Justice Legal Foundation filed. (Distributed)
  11. Feb 27 2025
    Motion of the Acting Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument filed.
  12. Feb 20 2025
    Brief of respondent Eric Guerrero, Director, Texas Department of Criminal Justice, Correctional Institutions Division filed. (Distributed)
  13. Feb 19 2025
    Record received electronically from the United States District Court for the Northern District of Texas and available with the Clerk.
  14. Feb 19 2025
    CIRCULATED
  15. Feb 18 2025
    Record received from the United States Court of Appeals for the Fifth Circuit. The record is electronic and is available on PACER.
  16. Feb 13 2025
    Record requested from the United States Court of Appeals for the Fifth Circuit.
  17. Feb 10 2025
    SET FOR ARGUMENT on Monday, March 31, 2025.
  18. Jan 28 2025
    Brief amici curiae of National Association of Federal Defenders and National Association of Criminal Defense Lawyers filed.
  19. Jan 28 2025
    Brief amici curiae of Professor Lee Kovarsky, et al. filed. (Corrected version)
  20. Jan 28 2025
    Brief amici curiae of Former Federal Judges filed.
  21. Jan 28 2025
    Brief amici curiae of Former Federal and State Prosecutors filed.
  22. Jan 28 2025
    Brief amicus curiae of Phillips Black, Inc. filed.
  23. Jan 28 2025
    Amici brief of Professor Lee Kovarsky, et al. not accepted for filing. (To be corrected - January 31, 2025)
  24. Jan 21 2025
    Brief of petitioner Danny Richard Rivers filed.
  25. Jan 21 2025
    Joint appendix filed. (Statement of costs filed)
  26. Dec 06 2024
    Petition GRANTED.
  27. Dec 02 2024
    DISTRIBUTED for Conference of 12/6/2024.
  28. Nov 18 2024
    DISTRIBUTED for Conference of 11/22/2024.
  29. Nov 14 2024
    Rescheduled.
  30. Oct 30 2024
    DISTRIBUTED for Conference of 11/15/2024.
  31. Oct 29 2024
    Reply of petitioner Danny Richard Rivers filed. (Distributed)
  32. Oct 11 2024
    Brief of respondent Bobby Lumpkin, Director, Texas Department of Criminal Justice in opposition filed.
  33. Aug 30 2024
    Motion to extend the time to file a response is granted and the time is extended to and including October 11, 2024.
  34. Aug 29 2024
    Motion to extend the time to file a response from September 11, 2024 to October 11, 2024, submitted to The Clerk.
  35. Aug 12 2024
    Response Requested. (Due September 11, 2024)
  36. Aug 07 2024
    DISTRIBUTED for Conference of 9/30/2024.
  37. Jul 26 2024
    Brief amicus curiae of National Association of Criminal Defense Lawyers filed.
  38. Jul 26 2024
    Brief amici curiae of Former Federal Judges filed.
  39. Jul 26 2024
    Brief amici curiae of Legal Scholars Lee Kovarsky, et al. filed.
  40. Jun 24 2024
    Petition for a writ of certiorari filed. (Response due July 26, 2024)