Reed v. Goertz
Headline: Court rules federal filing deadline for challenges to state post-conviction DNA testing starts when state appeals end, allowing prisoners to file federal due-process suits after state litigation concludes.
Holding: When a prisoner pursues state post-conviction DNA testing through the state process, the two-year limitation for a federal procedural due-process suit begins when the state litigation ends, here at rehearing denial.
- Gives prisoners more time to file federal due-process suits after state DNA testing denials.
- Discourages immediate federal suits while state appeals are pending.
- Makes timing of federal civil claims hinge on end of state litigation.
Summary
Background
Rodney Reed is a Texas inmate convicted in 1996 of murder and sentenced to death. In 2014 he asked Texas courts to order post-conviction DNA testing of many items, including the belt used to strangle the victim. The local prosecutor agreed to test some items but opposed most requests. The trial court denied Reed's motion, citing an inadequate chain of custody and concluding Reed had not shown he would have been acquitted. The Texas Court of Criminal Appeals affirmed and later denied rehearing. Reed then sued in federal court under 42 U.S.C. § 1983, arguing Texas's testing procedures violated procedural due process; the District Court dismissed and the Fifth Circuit held Reed's federal suit was filed too late.
Reasoning
The Court considered when a § 1983 procedural due-process claim for denied DNA testing becomes complete. It explained that such a claim is complete only when the State fails to provide due process. Because Texas's testing process includes trial and appellate review, the State's alleged failure was not final until the state litigation ended. The Court therefore held the two-year limitation period began when the Texas Court of Criminal Appeals denied rehearing, and it rejected Texas's challenges about standing, sovereign immunity, and Rooker–Feldman in this setting. The Court reversed the Fifth Circuit and ruled Reed's federal claim was timely.
Real world impact
The ruling affects people who seek post-conviction DNA testing and the prosecutors and courts that handle those requests. It lets someone wait until state appeals and rehearing are concluded before starting a federal due-process lawsuit about the state testing process. This decision resolves the timing question, not whether DNA testing should be granted in any particular case.
Dissents or concurrances
Two Justices dissented. Justice Thomas argued federal courts lacked jurisdiction and that Reed's suit impermissibly seeks appellate review of a state-court judgment. Justice Alito said the limitations period should have started earlier and would have affirmed the Fifth Circuit.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?