Lindh v. Murphy
Citation
521 U.S. 320 (1997). Supreme Court of the United States.
Facts
Joseph Lindh filed a federal habeas corpus petition before the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) was enacted. AEDPA imposed new, stricter standards for granting habeas relief. The question was whether those new standards applied to Lindh’s already-pending habeas case.
Issue
Did AEDPA’s new habeas standards apply to habeas cases that were already pending in federal court when AEDPA was enacted?
Holding
The Court held that AEDPA’s new standards for non-capital habeas cases (Chapter 153) did not apply to pending cases because Congress did not clearly express that intent, and applying new procedural standards to pending cases would have an impermissible retroactive effect.
Rule / Doctrine
The Landgraf two-step: (1) if Congress has expressly addressed retroactivity, apply that clear statement; (2) if not, determine whether applying the statute would have a genuinely retroactive effect on vested rights or liabilities — if so, the presumption against retroactivity bars application to pending cases. A negative inference is permissible: AEDPA’s Chapter 154 (death penalty cases) expressly applied to pending cases; the absence of a similar provision in Chapter 153 (noncapital cases) indicates Congress did not intend retroactive application there.
Significance
Lindh illustrates use of the presumption against retroactivity (Landgraf) and the negative inference canon. It teaches that structural comparison within a statute can resolve ambiguity and that Congress must speak clearly to impose retroactive burdens.