The “Single-New-Judgment” Doctrine
Resentencing on Any Count Restarts AEDPA’s Limitation Period for the Entire Conviction

Introduction

In Robert Kleckley v. State of Florida, No. 23-10887 (11th Cir. July 1, 2025), the Eleventh Circuit confronted a deceptively technical but practically important habeas-corpus question: Does a state prisoner’s resentencing on a single count create a “new judgment” that restarts the AEDPA one-year limitation period for all counts of conviction? The panel—Branch, Luck and Wilson, JJ.—answered “yes,” vacating a district court’s limitations dismissal and clarifying that a new judgment is indivisible: when a state court enters any new sentence, the resulting judgment resets AEDPA’s clock for the entire conviction package, even where other counts or sentences remain unchanged.

The case arose after Kleckley’s 2010 resentencing on Count 2 (shooting into an occupied vehicle) and his subsequent 2019 federal habeas petition challenging both that resentencing and his original 2000 trial/convictions (including Count 1, attempted first-degree murder). The district court treated Kleckley’s petition as untimely for claims tied to the 2000 trial, ruling that the 2010 proceeding did not constitute a new judgment. On appeal, the Eleventh Circuit granted a certificate of appealability on two interlocking questions about “new judgment” status and its reach.

Summary of the Judgment

• Holding 1: Kleckley’s April 9, 2010 resentencing on Count 2 did create a new judgment under the AEDPA framework, even though the state court imposed the same 30-year habitual-felony-offender sentence as before.
• Holding 2: That new judgment governs the entire conviction; therefore, all habeas claims—including challenges to untouched Count 1—are timely if filed within one year of the new judgment becoming final, subject to statutory tolling.
• Result: The Eleventh Circuit vacated the district court’s dismissal and remanded for merits consideration of all claims.

Analysis

Key Precedents Cited

The panel relied heavily on Supreme Court and Eleventh Circuit precedents that shape the meaning of “judgment” and “second or successive” petitions under AEDPA:

• Magwood v. Patterson, 561 U.S. 320 (2010) – Resentencing constitutes a new judgment, so a subsequent habeas petition is not “second or successive.”
• Patterson v. Sec’y, Fla. Dep’t of Corr. (en banc), 849 F.3d 1321 (11th Cir. 2017) – Emphasized that “the judgment pursuant to which the prisoner is in custody” is the operative judgment for AEDPA timing.
• Ferreira v. Sec’y, Dep’t of Corr., 494 F.3d 1286 (11th Cir. 2007) – Clarified that AEDPA’s limitations period starts when both conviction and current sentence are final.
• Murphy v. United States, 634 F.3d 1303 (11th Cir. 2011) – New judgment resets limitations; petitioner may challenge underlying conviction and resentencing alike.
• Insignares v. Sec’y, Fla. Dep’t of Corr., 755 F.3d 1273 (11th Cir. 2014) – Even partial resentencing (reducing mandatory minimum) produced a new judgment.
• Cassidy v. Sec’y, Fla. Dep’t of Corr., 119 F.4th 1336 (11th Cir. 2024) – Most recent judgment governs limitations; amended judgment replacing one count but leaving others unchanged was controlling.
• Nyland v. Moore, 216 F.3d 1264 (11th Cir. 2000) – Appellate remand rule: issues not decided below are remanded.

Legal Reasoning

The Court’s reasoning proceeds in two analytical moves.

1. “Judgment” includes both conviction and sentence.
   Drawing on Ferreira and Patterson, the panel emphasized that the AEDPA phrase “judgment of a State court” is indivisible: it amalgamates the adjudication of guilt and the sentence that authorizes custody. When a state court vacates a sentence and re-imposes any sentence—whether longer, shorter, or identical—it necessarily enters a new judgment.
2. A new judgment restarts the limitations clock for the entire case, not merely the modified count.
   Echoing Magwood, the Court reasoned that AEDPA’s limitation provision references an “application” rather than individual claims. Because there can be only one operative judgment at a time, and because the 2010 resentencing replaced Kleckley’s 2000 judgment, AEDPA’s one-year period began anew for all counts once that judgment became final.

The panel also addressed and rejected two district-court rationales: (i) Florida’s distinction between “judgment” and “sentence order” cannot alter federal habeas definitions; and (ii) the presence of an unchanged life sentence on Count 1 does not create dual limitation periods. Such a reading, the Court noted, conflicts with both statutory text and intra-circuit precedent (Cassidy, Insignares).

Potential Impact

• Eleventh-Circuit Uniformity: Confirms and strengthens Cassidy, eliminating lingering confusion in district courts about treating multi-count judgments as separate limitation-period silos.
• Strategic Implications for Practitioners: Defense counsel must note that any state-court resentencing—no matter how minor—can reopen federal habeas opportunities on all trial-level issues otherwise barred by time. Prosecutors, conversely, will scrutinize resentencing decisions knowing they may re-expose old convictions to collateral attack.
• State-Court Sentencing Practice: State judges and clerks may ensure their resentencing orders explicitly reference a “new judgment” to avoid ambiguity and unintended AEDPA consequences.
• Resource Allocation: Federal district courts in the Eleventh Circuit should expect more “revived” habeas petitions following narrow resentencings, necessitating fuller merits review instead of threshold dismissal.
• Supreme-Court Trajectory: By adopting a bright-line “single-new-judgment” rule, the Eleventh Circuit aligns with Magwood yet goes further on multi-count cases; other circuits may clash, inviting eventual Supreme Court clarification.

Complex Concepts Simplified

• AEDPA One-Year Limitation (§ 2244(d)(1)) – A federal habeas corpus petition must be filed within one year of the judgment becoming “final,” usually when direct review ends.
• “Judgment” – For AEDPA, a composite of conviction and the sentence currently authorizing custody. A modification of either element yields a new judgment.
• “Second or Successive” Petition – A later habeas petition filed after an earlier one has been resolved. If a new judgment intervenes, the later petition is treated as an initial petition, not “second or successive.”
• Tolling (§ 2244(d)(2)) – Time during which a “properly filed” state post-conviction motion is pending is subtracted from the one-year clock.
• Rule 3.800(a) (Florida) – Procedural rule permitting defendants to correct illegal sentences at any time.
• Concurrent Sentences – Sentences served at the same time; changing one still alters the overall judgment.

Conclusion

Kleckley cements a clear Eleventh-Circuit principle: any resentencing event, however isolated, triggers a new, unitary judgment that restarts AEDPA’s one-year limitations period for the entire conviction. The ruling harmonizes the Circuit’s statute-of-limitations and second-or-successive jurisprudence, aligning with the Supreme Court’s structural reading of AEDPA while providing a simple, administrable rule. Going forward, federal courts must treat habeas petitions filed within a year of a partial resentencing as timely with respect to all claims, absent other procedural bars—an outcome that both broadens prisoners’ access to federal review and heightens the strategic stakes of state-court resentencings.