Georgia death row prisoner Dorian O’Kelley challenged the dismissal of several subclaims in his federal habeas petition for insufficient detail. Some dismissals were made by the district court on its own initiative, and it later denied his request to amend. The Eleventh Circuit framed the appeal narrowly: whether the Constitution required advance notice and a chance to repair the pleading in these circumstances. The majority held that it did not and affirmed denial of the petition; it did not announce a general rule that notice is never useful. Judge Rosenbaum dissented in part, arguing that the record did not justify denying amendment for undue delay after the court first identified the supposed defects years into the case. The ruling concerns federal habeas procedure, not a fresh assessment of O’Kelley’s guilt.