context: In Lindh v. Murphy, which concerned the retroactive effect of AEDPA's provision heightening the standards for the availability of habeas relief in noncapital cases, the Supreme Court elaborated further on the initial step of the Landgraf analysis. Finding that silence as to temporal reach in one provision of the statute implied prospectivity where Congress had expressly provided for retroactivity to pending cases in another provision, the Lindh Court established negative implication as one of the "normal rules of statutory construction" to be used by the courts in determining a statute's temporal reach.
citation_a.signal: cf.
citation_a.parenthetical: describing Lindh as having added a "new step" to the Landgraf analysis
citation_a.sentence: See also Mayers, 175 F.3d at 1302 {“Lindh expands the tools available to courts to determine congressional intent”); Sandoval, 166 F.3d at 240 (“the Lindh Court made clear that the rule of negative implication is part of the normal rules of statutory construction”); cf. Mathews v. Kidder Peabody & Co., 161 F.3d 156 (3d Cir.1998) (describing Lindh as having added a “new step” to the Landgraf analysis).
citation_b.signal: see also
citation_b.identifier: 166 F.3d 240, 240
citation_b.parenthetical: "the Lindh Court made clear that the rule of negative implication is part of the normal rules of statutory construction"
citation_b.sentence: See also Mayers, 175 F.3d at 1302 {“Lindh expands the tools available to courts to determine congressional intent”); Sandoval, 166 F.3d at 240 (“the Lindh Court made clear that the rule of negative implication is part of the normal rules of statutory construction”); cf. Mathews v. Kidder Peabody & Co., 161 F.3d 156 (3d Cir.1998) (describing Lindh as having added a “new step” to the Landgraf analysis).