Howell: Change in interpretation of limitations not extraordinary

In Howell v. Sec., Fla. Dep’t of Corrections, No. 13-10766 (Sept. 13, 2013) the Court affirmed the denial of habeas relief to Florida inmate sentenced to death for a 1992 murder, finding the petition to be time-barred. Howell claimed that a Supreme Court decision that altered the interpretation of the statute of limitations for a petition for a writ of habeas corpus was an “extraordinary circumstance” that warranted relief from the denial of a habeas petition under Federal Rule of Civil Procedure 60(b). Rejecting this argument, the Court held that under Gonzalez v. Crosby, this did not qualify as an “extraordinary circumstance.”