Brown v. Muniz

The Ninth Circuit denied petitioner's application for leave to file a second or successive habeas petition with the district court. The panel held that petitioner's Brady v. Maryland claim was subject to the Antiterrorism and Effective Death Penalty Act's (AEDPA) second or successive gatekeeping requirements because the factual predicate supporting a Brady claim existed at the time of the first habeas petition. The panel applied AEDPA's second or successive bar to petitioner's Brady claim and held that he has failed to make the requisite prima facie showing of actual innocence. View "Brown v. Muniz" on Justia Law