Reed v. Goertz
Headline: Timing for federal lawsuits over post‑conviction DNA testing: Court ruled the federal filing deadline starts when state appeals and rehearing end, reversing the Fifth Circuit and making federal claims timely after state litigation finishes.
Holding:
- Federal deadline for DNA‑testing lawsuits runs after state appeals finish.
- Prisoners must complete state post‑conviction review before federal time clock starts.
- Discourages parallel federal suits while state appeals proceed.
Summary
Background
Rodney Reed is a man convicted and sentenced to death for a 1996 murder in Texas. In 2014 he asked Texas courts to order DNA testing on many pieces of evidence, including the belt used to strangle the victim. The trial court denied testing in part because it found an inadequate chain of custody and skepticism that any results would show he was innocent. The Texas Court of Criminal Appeals affirmed and denied rehearing.
Reasoning
The question was when a federal lawsuit challenging state DNA‑testing procedures becomes time‑barred. The Court explained that a procedural‑due‑process claim is only complete when the State has finished the process and failed to provide fair procedures. Because Texas’s process includes appellate review and rehearing, the federal two‑year clock begins when state litigation ends — here when the Court of Criminal Appeals denied rehearing. The Court also rejected Texas’s threshold challenges about standing, sovereign immunity, and improper federal review.
Real world impact
The decision means prisoners who seek post‑conviction DNA testing in states with an appellate process must count the federal filing deadline from the end of state appeals. It reduces the risk of premature federal suits filed while state review is ongoing and encourages full use of state procedures first. The ruling decides only timing, not whether Texas’s law is constitutional.
Dissents or concurrances
Several Justices disagreed. One dissent argued federal courts lacked jurisdiction because Reed’s suit effectively sought appellate review of the state court’s judgment; another dissent said the limitations period could have started earlier, when lower state courts ruled.
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