When Actual Innocence Is Irrelevant: Federal Habeas Relief for State Prisoners after \u3ci\u3eHerrera v. Collins\u3c/i\u3e

In Herrera v. Collins, the United States Supreme Court held that federal habeas courts lack jurisdiction over claims of actual innocence based on newly discovered evidence because federal habeas courts ensure only that state prisoners are not held in violation of the United States Constitution. This Note argues that state prisoners are held in violation of the Constitution when state procedural rules constructively bar presentations of newly discovered evidence of innocence. This Note proposes that federal habeas courts should grant 1) an evidentiary hearing when a petitioner makes a substantial allegation of newly discovered evidence of innocence, and 2) relief when that evidence proves that the trier of fact probably would have had reasonable doubt as to the petitioner\u27s guilt