Clay v. United States
Headline: Court rules federal prisoners’ one-year relief clock starts when time to seek Supreme Court review expires, overturning lower-court mandate rule and helping many late postconviction filings.
Holding: For the purpose of §2255’s one-year limit, a conviction becomes final when the time to file a petition for Supreme Court review expires, not when the court of appeals’ mandate issues.
- Starts the one-year clock when certiorari time expires for federal prisoners.
- Makes some previously time-barred §2255 motions timely.
- Resolves a split among courts of appeals on timing.
Summary
Background
A federal prisoner, Erick Cornell Clay, was convicted of arson and distributing cocaine base. The Seventh Circuit affirmed his conviction and issued its mandate in December 1998. Clay did not ask the Supreme Court to review the case, and the time to file a petition for review expired in February 1999. Clay filed a motion under the federal law 28 U.S.C. §2255 in February 2000. The district court and the Seventh Circuit held the motion time-barred because they treated the judgment as final when the court of appeals issued its mandate.
Reasoning
The Court addressed a single question: for a federal defendant who does not seek Supreme Court review, when does the one-year clock for a §2255 motion begin—when the appeals court issues its mandate or when the time to file a Supreme Court petition ends? The Court explained that finality for collateral review has long meant the date when the time for seeking this Court’s review expires (or when this Court acts on review). Relying on that established understanding and the majority of lower-court decisions, the Court rejected the mandate rule and held the one-year period begins when the certiorari period expires. The Seventh Circuit’s judgment was reversed, and the case was returned to the lower court.
Real world impact
The decision sets a single rule for federal prisoners bringing §2255 motions: the one-year limit runs from the date the time to seek Supreme Court review expires. That makes some filings previously held time-barred timely in affected circuits and resolves a split among courts of appeals. The case was remanded for further proceedings consistent with this ruling.
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