Innocence claims and deadlines
McQuiggin v. Perkins
In brief
The Supreme Court wiped out the appeals court’s ruling and sent the case back; the district court’s finding that Perkins fell short of the innocence test should control unless there is cause to disturb it.
- Where it stands
- Decided
Decided 5-4 · May 28, 2013 · Opinion by Justice Ginsburg
- What it’s about
- Floyd Perkins sought to use an actual-innocence claim to get review of a late federal challenge to his conviction.
- Who it affects
- The Sixth Circuit should treat the district court’s finding that Perkins failed the demanding innocence test as decisive unless there is cause to set it aside; the Supreme Court said it saw none.
Summary: written with AI from the case record.
What it's about
The Supreme Court wiped out the appeals court’s ruling and sent the case back (vacated and remanded), saying the trial court’s finding that Perkins had not met the demanding innocence standard should stand unless there was a reason to disturb it.
Schlup’s demanding test asks whether an actual-innocence claim can open the way for a court to review an otherwise blocked petition.
Question presented
1. Must an accused claiming actual innocence prove that extraordinary circumstances prevented the timely filing of his habeas petition? 2. If so, must an accused pursue an actual innocence claim with the same reasonable diligence required to toll the statute of limitations for other habeas petition claims?
What the Court decided
Holding
Here, the District Court’s appraisal of Perkins’ petition as insufficient to meet Schlup ’ s actual-innocence standard should be dispositive, absent cause, which this Court does not currently see, for the Sixth Circuit to upset that evaluation. Under Schlup’s demanding standard, the gateway should open only when a petition presents “evidence of innocence so strong that a court cannot have confidence in the outcome of the trial unless the court is also satisfied that the trial was free of nonharmless constitutional error.” 513 U. S., at 316. 670 F. 3d 665, vacated and remanded.
- Result
- Vacated
The Court's reasoning
The Court said the Sixth Circuit should accept the district court’s finding that Perkins fell short of Schlup’s demanding innocence test unless there was cause to disturb it; the Court said it saw none. The test requires evidence so strong that a court cannot trust the trial result unless it is also satisfied that no harmful constitutional error affected the trial.
The vote
From the opinions
““This Court has no such power, and not one of the cases cited by the opinion says otherwise.””
What's next
The case returns to the Sixth Circuit. It should follow the Supreme Court’s instruction and treat the district court’s assessment as decisive unless there is cause to disturb it.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - McQuiggin
Opinion added: McQuiggin
More questions
- What did Justice Scalia object to?
- He argued that the Court could not create an exception to Congress’s one-year deadline for state prisoners’ federal challenges because Congress had not enacted one.
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.