Phelps Dodge Corp. v. United States

holding that prison "mailbox rule” applies to state as well as federal habeas petitions | holding that prison "mailbox rule” applies to state as well as federal habeas petitions | suggesting that penalty phase faults might have been sufficient for habeas relief had guilt phase faults not been sufficient for relief | suggesting that penalty phase faults might have been sufficient for habeas relief had guilt phase faults not been sufficient for relief | noting the complexity of cases where “an ingredient can arguably be both ah element of a charged crime and of a defense, or the presence of a defense can arguably negate a required element” | declining, in capital case, to consider jurors’ evidence that, during deliberations, jurors referred to African-American defendant’s race and his interracial relation ship, and made racial jokes | under “mailbox rule” of Houston v. Lack, 487 U.S. 266, 108 S.Ct. 2379, 101 L.Ed.2d 245 (1988), habeas corpus petition is properly filed on the date petitioner delivers petition to prison authorities for mailing