Deadlines for prison challenges
Wall v. Kholi
In brief
The Court ruled that a Rhode Island Rule 35 request to reduce a sentence pauses the federal one-year deadline for challenging the sentence.
- Where it stands
- Decided
Decided 9-0 · March 7, 2011 · Opinion by Justice Scalia
- What it’s about
- Khalil Kholi’s Rhode Island Rule 35 request to reduce his sentence raised whether it paused the one-year deadline for his federal court challenge to his imprisonment.
- Who it affects
- A Rhode Island Rule 35 motion to reduce a sentence pauses the federal one-year deadline for an inmate’s challenge to that sentence.
Summary: written with AI from the case record.
What it's about
The Supreme Court agreed with the First Circuit (affirmed) that it did, because the request sought post-conviction review outside a direct appeal (collateral review).
Federal law gives inmates one year to challenge their imprisonment in federal court and pauses that deadline during some state-court review; this case concerned a request to reduce a sentence.
Question presented
Inmates have one year to file a habeas challenge to their sentence in federal court after conviction. The running of that time is delayed while the conviction is under review in state court. Is the time also tolled while a state court considers an inmate's request for a sentence reduction?
What the Court decided
Holding
A Rule 35 motion to reduce sentence under Rhode Island law is an application for “collateral review” that triggers AEDPA’s tolling provision. 582 F. 3d 147, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court treated a Rhode Island Rule 35 motion as post-conviction review outside a direct appeal (collateral review). That classification triggers the federal rule that pauses the one-year deadline.
The vote
What's next
The First Circuit’s ruling remains in place. Federal courts must treat the time a Rhode Island court considers a Rule 35 sentence-reduction motion as paused on the one-year clock.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Case Briefing
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Case data updated: question_presented, extraction_metadata
Case data updated: summary, question_presented, generation_metadata
Audio Recording added: Oral Arguments - Wall
Opinion added: Wall
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.