In the case of Deneice A. Mayle, Warden v. Jacoby Lee Felix (2004), the U.S Supreme Court ruled in favor of Mayle, reversing a Ninth Circuit decision that had granted habeas corpus relief to Felix. The issue at hand was whether or not an amended habeas petition filed after the one-year statute of limitations set by Antiterrorism and Effective Death Penalty Act (AEDPA) could relate back to the original timely-filed petition under Federal Rule of Civil Procedure 15(c). Felix argued that his second claim should be considered as it arose from "the same core facts" as his first claim and thus fell within Rule 15(c)'s scope for relation back. However, the Supreme Court disagreed with this broad interpretation and held that an amendment can only relate back if it asserts a claim arising from "the same conduct, transaction or occurrence" detailed in the original pleading - which wasn't applicable here since each alleged violation constituted separate occurrences.

In the dissenting opinion for Deneice A. Mayle, Warden v. Jacoby Lee Felix, it was argued that the majority's decision to allow a habeas corpus petition filed after one year from conviction was incorrect and not in line with the Antiterrorism and Effective Death Penalty Act (AEDPA). The dissenting justices believed that this ruling would open up an opportunity for convicted criminals to delay their sentences indefinitely by filing successive petitions. They also pointed out that there were no extraordinary circumstances in Felix’s case which could justify such a late filing of his petition. Furthermore, they disagreed with the majority's interpretation of "factual predicate," arguing instead that it should be interpreted as when facts supporting claims become available rather than when legal basis becomes apparent.