Mayle v. Felix’s Empirical Analysis
2005
Citation profile
199 federal appellate · 165 district · 57 state decisions
How this case has been cited
Cited by 926 later decisions (4 by the Supreme Court) — most recently January 2026 · most notably Day v. McDonough (2006), Jimenez v. Quarterman (2009)
199 federal appellate · 165 district · 57 state decisions — followed in 17 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedFelix v. Mayle (from Ninth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 2242 (Antiterrorism and Effective Death Penalty Act of 1996) · 28 U.S.C. § 2244 (Antiterrorism and Effective Death Penalty Act of 1996) · 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996) · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 45 U.S.C. § 51 (Federal Employers' Liability Act)
Relies on Strickland v. Washington · Conley v. Gibson · Brady v. State of Maryland · Foman v. Davis · Heck v. Humphrey
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 926 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“does not relate back (and thereby escape AEDPA's one-year time limit) when it asserts a new ground for relief supported by facts that differ in both time and type from those the original pleading set forth.”
12 later decisions quote this exact passage · from the majority“depends on the existence of a common core of operative facts uniting the original and newly asserted claims,”
9 later decisions quote this exact passage · from the majoritye.g. Ross v. Williams · Beason v. Marske“(1) When an Amendment Relates Back. An amendment to a pleading relates back to the date of the original pleading when: (A) the law that provides the applicable statute of limitations allows relation back; (B) the amendment asserts a claim or defense that arose out of the conduct, transaction, or occurrence set out-or attempted to be set out-in the original pleading; or (C) the amendment changes the party or the naming of the party against whom a claim is asserted, if Rule 15(c)(1)(B) is satisfied and if, within [90 days of the filing of the relevant pleading], the party to be brought in by amendment: (i) received such notice of the action that it will not be prejudiced in defending on the merits; and (ii) knew or should have known that the action would have been brought against it, but for a mistake concerning the proper party's identity. (2) Notice to the United States . When the United States or a United States officer or agency is added as a defendant by amendment, the notice requirements of Rule 15(c)(1)(C)(i) and (ii) are satisfied if, during the stated period, process was delivered or mailed to the United States attorney or the United States attorney's designee, to the Attorney General of the United States, or to the officer or agency.”
8 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.