Danny Richard Rivers v. Guerrero
In brief
The Court said a later habeas filing after the first federal trial court's judgment is a repeat application subject to strict limits, and the Fifth Circuit's ruling stands.
- Where it stands
- Decided
Decided 9-0 · June 12, 2025 · Opinion by Justice Jackson
- What it’s about
- The Supreme Court held that any federal habeas petition filed after a district court has entered judgment on a first petition counts as a "second or successive" application subject to strict procedural limits, even if an appeal of the first petition is still pending.
- Who it affects
- The first federal trial court's judgment triggers strict limits on later federal habeas filings. Lower courts must apply §2244(b)'s filing requirements after that judgment.
Summary: written with AI from the case record.
What it's about
This ruling clarifies that the entry of judgment, rather than the conclusion of the appellate process, triggers the Antiterrorism and Effective Death Penalty Act's restrictions on repeat filings.
Federal habeas law lets prisoners challenge their imprisonment but places strict limits on repeat filings.
Question presented
Does 28 U.S.C. § 2244(b)(2) apply to all second habeas petitions, or only specific types of second petitions?
What the Court decided
Holding
Once a district court enters its judgment with respect to a firstfiled habeas petition, a second-in-time filing qualifies as a “second or successive application” properly subject to the requirements of §2244(b). 99 F. 4th 216, affirmed.
- Result
- Affirmed
The vote
What's next
The Fifth Circuit's ruling remains in place. Lower courts will use the first federal trial court's judgment to identify later repeat applications and apply §2244(b)'s strict filing rules.
Documents
Docket activity
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More questions
- What did the Supreme Court decide in Rivers v. Guerrero?
- It ruled that a filing after a district court enters judgment on the first habeas petition is a “second or successive” application under §2244(b).
- Did the Supreme Court uphold the Fifth Circuit's ruling?
- Yes. The Court ruled unanimously, and Justice Jackson delivered the opinion.
- When do §2244(b)'s repeat-filing limits begin for Rivers?
- They apply once a district court enters judgment on Rivers's first habeas petition. A later filing then faces §2244(b)'s strict requirements.
- How will lower courts apply the Rivers ruling to later filings?
- They will treat a filing after that judgment as a “second or successive” application and apply §2244(b)'s strict filing rules.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.