Wall v. Kholi
The Supreme Court ruled that a Rhode Island prisoner's motion asking a judge to reduce his sentence counts as "collateral review" under federal habeas law, meaning it paused the one-year deadline for filing a federal habeas petition.
Because that motion paused the clock, the prisoner's later federal habeas petition was filed on time, and the Court adopted a broad definition of "collateral review" covering any judicial reexamination of a case outside the direct-appeal process.
How it got here: A federal district court dismissed Kholi's habeas petition as untimely; the First Circuit reversed, and the prison warden asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Khalil Kholi was convicted in Rhode Island of first-degree sexual assault and given consecutive life sentences. After his direct appeal failed, he filed a state motion asking the judge to reduce his sentence and, separately, an application for state post-conviction relief challenging his conviction. Both were eventually denied, and Kholi then filed a federal habeas corpus petition.
The question before the Court
If a Rhode Island prisoner asks a judge to reduce his sentence, does that request pause the one-year clock for filing a federal habeas petition?
Why it matters
State prisoners nationwide now know that filing a state motion to reduce their sentence — even one asking only for leniency rather than raising a legal error — pauses the federal habeas filing clock. This gives prisoners more breathing room to pursue state remedies without accidentally missing their one-year federal deadline, and it resolves a split among federal appeals courts on the question.
What changes now
This is a final merits decision resolving the legal question of what counts as "collateral review" under the federal habeas tolling statute. The judgment for Kholi is affirmed, meaning his federal habeas petition is treated as timely and can proceed on the merits in the lower courts. The ruling also settles a split among federal appeals courts, so lower courts nationwide will now apply this broader definition when deciding whether other state sentence-reduction motions pause the federal filing deadline.
What this does not decide
The Court expressly did not decide whether Rhode Island's sentence-reduction motion might instead count as part of "direct review" itself, since the parties never raised that argument; it noted the outcome would be the same either way.
Concurrences and dissents
Concurrence in part — Justice Scalia
Justice Scalia agreed with the Court's core conclusions — that "collateral review" means non-direct review and that Rhode Island's Rule 35 motion qualifies as collateral review. However, he refused to join a footnote in which the majority declined to decide whether a Rule 35 motion might actually be part of direct review instead, apparently preferring the majority resolve that loose end rather than leave it open.
How the Court got there
The legal reasoning, step by step
- The Court had to define "collateral review," an undefined phrase in the federal habeas statute's tolling provision, which pauses the one-year filing deadline while certain state proceedings are pending.
- Looking at ordinary dictionary meaning and the related term "collateral attack," the Court concluded that "collateral" simply means indirect or not part of the main line of action — so "collateral review" means judicial review that is not part of direct appeal.
- The Court reinforced this by noting its own past decisions had used "collateral" to describe habeas corpus, motions under the old federal Rule 35, and other proceedings that all stood apart from direct appeal.
- Applying this definition, the Court found that Rhode Island's Rule 35 sentence-reduction motion is not part of direct appeal and involves a judge's genuine reexamination of the sentence using specific factors, so it clearly counts as both "collateral" and "review."
- The Court rejected Rhode Island's narrower reading — that "collateral review" covers only motions challenging the legal validity of a sentence, not requests for leniency — because nothing in the statute's text or purpose supports limiting the phrase that way.
- The Court also rejected the idea that whether a motion is filed within the same criminal case, rather than as a separate proceeding, should determine whether it counts as "collateral," since that distinction varies inconsistently across states and existing precedent.