WILSON, Circuit Judge:
Veronza L. Bowers, who is serving a life sentence for the 1976 murder of a United States Park Ranger, appeals the district court's denial of his motions for discovery and leave to amend his petition for a writ of habeas corpus, as well as the district court's determination that the United States Parole Commission did not violate the mandate handed down by this court in Bowers v. Keller, 651 F.3d 1277 (11th Cir. 2011) (per curiam). Because the district court took an overly narrow view of our mandate, we conclude that the district court abused its discretion in denying Bowers's motions for discovery and leave to amend.
On May 17, 2005, Bowers received a Notice of Action from the Parole Commission, notifying him that he had been granted mandatory parole,
The Parole Commission met on October 6, 2005, after receiving comments from both the Attorney General and Bowers, and voted to deny mandatory parole. The Parole Commission unanimously agreed that an escape attempt made by Bowers in 1979 constituted a serious violation of institution rules, thus precluding the Parole Commission from granting mandatory parole. See 18 U.S.C. § 4206(d). Additionally, a majority of the Parole Commission determined that Bowers was "likely to commit a crime in the future" based on its belief that the murder committed by Bowers "was motivated by [his] attitude towards and hatred for the United States Government, its employees, and its law enforcement" and that Bowers still held those feelings.
After the Parole Commission made its decision, Bowers learned of Commissioner Spagnoli's memorandum and filed a petition for a writ of habeas corpus in the Northern District of Georgia, challenging the Parole Commission's decisions to re-open his case, first on February 17, 2005, under 28 C.F.R. § 2.28(f) and again on June 14, 2005, under 28 C.F.R. § 2.27. The district court denied Bowers's petition, noting that the Parole Commission never lacked "jurisdiction or authority to revise its decision to grant or deny [Bowers's] parole."
Bowers appealed, and we reviewed the actions taken by the Parole Commission, noting that we would not reverse the Parole Commission's decisions "unless [they] involve[d] flagrant, unwarranted, or unauthorized action that constitutes an abuse of the Commission's discretion." Keller, 651 F.3d at 1291 (internal quotation marks omitted). We found that the Parole Commission's June 14 decision was "impermissibly tainted by Commissioner Spagnoli's unauthorized actions revealing her bias."
Because Spagnoli did not act "as an independent and neutral decision-maker at the time of the Parole Commission's June 14, 2005 decision," Keller, 651 F.3d at 1293, we vacated that decision and directed the district court to "return this case to the Parole Commission in its posture as of May 17, 2005," id. at 1295. We instructed the Parole Commission to "immediately review Bowers'[s] case to determine whether any further action is necessary or authorized," and directed the district court to grant Bowers's petition "[u]nless the Parole Commission initiate[d] proceedings within sixty (60) days." Id. at 1296. Further, we noted that there was no evidence
On September 29, 2011, the Parole Commission informed Bowers that it would be reviewing the record to determine whether to hold a re-vote of Bowers's case. The Parole Commission stated that it would be reviewing materials from before and after May 2005 and set an October 14, 2011 deadline for submitting new materials. Instead of waiting until after the deadline to conduct the record review, the Parole Commission, without giving notice or explanation, conducted the record review on October 4, 2011, and decided to re-vote Bowers's case.
After exhausting his administrative appeals, Bowers moved for discovery
On appeal, Bowers asks us to reverse the district court's denial of the motions for discovery and leave to amend, as well the district court's decision that the Parole Commission did not violate its own rules and regulations. For the reasons set forth below, we hold that the district court abused its discretion by denying Bowers's motions for discovery and leave to amend. We affirm the district court on all other grounds.
The denial of habeas corpus relief under 28 U.S.C. § 2241 is reviewed de novo. Keller, 651 F.3d at 1291. We review a district court's denial of a motion for leave to amend for abuse of discretion. Thomas v. Farmville Mfg. Co., 705 F.2d 1307, 1307 (11th Cir.1983) (per curiam). However, "[u]nless there is a substantial reason to deny leave to amend, the discretion of the district court is not broad enough to permit denial." Thomas v. Town of Davie, 847 F.2d 771, 773 (11th Cir.1988) (internal quotation marks omitted). We review the district court's denial of discovery for abuse of discretion. Arthur v. Allen, 452 F.3d 1234, 1243, modified on reh'g, 459 F.3d 1310 (11th Cir.2006) (per curiam).
Unlike typical civil litigants, habeas petitioners are "not entitled to discovery as a matter of ordinary course." Bracy v. Gramley, 520 U.S. 899, 904, 117 S.Ct. 1793, 1796-97, 138 L.Ed.2d 97 (1997). It is within the discretion of the district court to grant discovery upon a showing of good cause. Id. at 904, 117 S.Ct. at 1797 (quoting Rule 6(a) of the Rules Governing Section 2254 Cases).
In denying Bowers's motion for discovery, the district court did not consider whether Bowers had demonstrated good cause. Instead, it interpreted the absence of an instruction to conduct discovery
We find it necessary to clarify several points from our opinion in Keller. First, contrary to the district court's interpretation, we did not make any ruling on Bowers's claims that "the Parole Commission's October 6, 2005 decision was tainted by political pressure." In Keller, we reversed the district court's denial of habeas relief based on our determination that the Parole Commission's June 14, 2005 order had to be vacated because Commissioner Spagnoli's actions violated the Parole Act's mandate that the Parole Commission function as an independent agency. Keller, 651 F.3d at 1295. In doing so, we "necessarily vacate[d] the Parole Commission's October 6, 2005" decision, id., which Bowers alleged was tainted by political pressure, id. at 1290. Because we had already vacated the October 6, 2005 decision, there was no reason to consider Bowers's political pressure claims. Accordingly, the district court should not have denied discovery on the grounds that we had already decided this issue.
Second, although we did not explicitly instruct the district court to determine whether discovery would be necessary, the absence of such an instruction should not be read to preclude discovery. We mandated that Bowers's case be returned to its posture as of May 17, 2005 because it was clear that the Parole Commission, by virtue of Commissioner Spagnoli's actions, had failed to act independently and without bias. See id. at 1295-96. While our opinion noted that no evidence suggested that the current Parole Commission would be unable to provide Bowers a "fair and impartial hearing," id. at 1296, it did not foreclose the possibility that subsequent evidence could give rise to such a conclusion. Our mandate sought to ensure that Bowers would receive his parole decision in the absence of bias. The district court abused its discretion by reading our mandate so narrowly as to preclude discovery into whether the Parole Commission acted independently and without bias. See United States v. Mesa, 247 F.3d 1165, 1170 (11th Cir.2001) ("The district court must implement both the letter and spirit of the mandate, taking into consideration our opinion and the circumstances it embraces.").
To be sure, the district court was right to avoid addressing matters that were outside the scope of our mandate. See United States v. Tamayo, 80 F.3d 1514, 1520 (11th Cir.1996) (noting that a district court abuses its discretion by asserting jurisdiction over issues not within the scope of a mandate from this court). However, in doing so, the court took too narrow a view of our mandate's scope and abused its discretion by failing to give Bowers's request for discovery fair consideration.
Bowers alleges that external political pressure prevented the Parole Commission from acting as an unbiased, independent agency when deciding his case. He points to past allegations of political considerations influencing the Parole Commission's decisions, as well as the suspicious timing of the October 4, 2011 decision
Rule 15(a) of the Federal Rules of Civil Procedure allows a party to amend pleadings with leave from the court. Fed. R.Civ.P. 15(a)(2). Leave to amend should be granted "when justice so requires." Id. District courts have limited discretion in denying leave to amend, and should grant a motion to amend "[u]nless there [are] substantial reason[s] to deny" it. Espey v. Wainwright, 734 F.2d 748, 750 (11th Cir. 1984) (per curiam) (first alteration in original) (internal quotation marks omitted).
As with its decision to deny discovery, the district court's decision to deny leave to amend was informed largely by its overly narrow interpretation of our mandate. It also noted that Bowers's habeas petition was already "long and complicated." Neither explanation amounts to a "substantial reason" for denying a motion to amend. Accordingly, the court abused its discretion in denying leave to amend.
For the foregoing reasons, we hold that the district court abused its discretion in denying Bowers's motions for discovery and leave to amend. We reverse and remand for proceedings in accordance with this opinion. We affirm the district court on all other grounds.