Artuz v. Bennett

Background

A man convicted in New York after a 1984 jury trial sought to challenge his conviction in state court in 1995. The trial court denied his 1995 motion orally on November 30, 1995, and he says he never received a written order. In February 1998 he filed a federal habeas petition, which the district court dismissed as untimely under the one-year deadline created by the Antiterrorism and Effective Death Penalty Act (AEDPA). The Second Circuit reversed, treating the 1995 state motion as still "pending" and concluding it was "properly filed" for tolling purposes.

Reasoning

The Court considered whether a state postconviction application is "properly filed" under 28 U.S.C. §2244(d)(2) when it contains claims that state law would bar on procedural grounds. The Court said "properly filed" refers to whether the application was delivered and accepted in compliance with filing rules (form, time limits, place, fees), not to whether each claim in the application avoids state procedural bars. State rules that simply direct a court to deny relief when a claim was previously decided or could have been raised on direct appeal set rules of decision, not conditions to filing. Because those state bars do not prevent a motion from being filed and accepted, they do not make the motion "improperly filed." The Court therefore affirmed the court of appeals.

Real world impact

The ruling means that state prisoners who file state postconviction motions that are accepted by the clerk can pause the federal AEDPA clock even if some claims in those motions are procedurally barred under state law. The Court acknowledged policy concerns — such as burdens on courts and the possibility of protective filings — but said the statutory text controls and it would not rewrite the law to address those concerns.