Motion to Amend Habeas Petition Considered to be a Successive Petition

U.S. v. Nelson, 2006 WL 2848113 (10/6/06) - Habeas petitioner's motion to amend petition after his initial petition was denied was actually a successive petition subject to the impossible-to-meet successive petition standards. The 10th must look beyond the title of the motion to its substance, which was to add substantive claims the petitioner had not raised initially.