Reed v. Goertz
Headline: Court rules that the two-year federal time limit for suing over state post-conviction DNA-testing procedures begins when state appeals end, affecting prisoners who challenge state DNA rules.
Holding: The Court decided that a prisoner's federal procedural due-process suit under § 1983 challenging state post-conviction DNA testing rules accrues and starts its two-year clock when the state appellate process, including rehearing, ends.
- Starts two-year clock when state appeals, including rehearing, finish.
- Lets prisoners sue in federal court after state appeals conclude.
- Reduces parallel federal-state litigation over DNA testing requests.
Summary
Background
Rodney Reed, a death-row prisoner convicted in 1996 for the murder of Stacey Stites, asked Texas courts in 2014 to order post-conviction DNA testing of evidence, including the belt used to strangle the victim. The local prosecutor agreed to test a few items but opposed most testing. The state trial court denied Reed’s motion partly because many items lacked an adequate chain of custody and Reed had not shown exculpatory results would likely lead to acquittal. The Texas Court of Criminal Appeals (CCA) affirmed and denied rehearing. Reed then sued a Texas prosecutor in federal court under 42 U.S.C. § 1983, claiming Texas’s DNA-testing procedures violated procedural due process; the District Court dismissed, and the Fifth Circuit held Reed filed too late, saying the limitations period began when the trial court denied the motion.
Reasoning
The only question the Supreme Court decided was when the two-year statute of limitations for Reed’s § 1983 procedural-due-process claim began to run. The Court explained a procedural-due-process claim is complete not when the alleged deprivation occurs but when the State has definitively failed to provide fair process. Texas’s process includes trial and appellate review, and Texas appellate procedure covers a motion for rehearing. Therefore the Court held the limitations period began when the state litigation ended—when the CCA denied rehearing—so Reed’s federal suit was timely. The Court also rejected Texas’s threshold arguments about standing, sovereign immunity (noting Ex parte Young), and Rooker-Feldman.
Real world impact
The ruling means prisoners who pursue state post-conviction DNA testing and then challenge the state process in federal court have their two-year clock start after state appeals, including rehearing, end. That approach encourages completion of state appeals before federal suits and avoids duplicative parallel litigation, while leaving open the merits question whether particular state rules are constitutional.
Dissents or concurrances
Justice Thomas dissented arguing the federal courts lacked subject-matter jurisdiction and that Reed’s complaint sought effective appellate review of a state-court judgment; Justice Alito (joined by Justice Gorsuch) dissented that accrual should have been earlier and would have affrmed the Fifth Circuit.
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