No. 19-6767October Term 2019Decided Apr 27, 2020
True v. Kelley
The Supreme Court did not use this case to answer when mental illness or lack of legal materials can excuse a late filing.
Case status
- Current stage
- Decided
- Latest event
- Decision released Apr 27, 2020
- What it's about
This is a pending petition for a writ of certiorari filed in forma pauperis from the United States Court of Appeals for the Eighth Circuit.
Question presented
1. Whether the district court erred in dismissing Petitioner's 28 U.S.C. § 2254 petition as untimely, where Petitioner was entitled to equitable tolling because his mental illness and the lack of access to legal materials prevented him from filing his petition on time? 2. Whether the district court erred in failing to conduct an evidentiary hearing on Petitioner's claim for equitable tolling?
- Case path
United States Court of Appeals for the Eighth Circuit / Decision released Apr 27, 2020
- Area
Decided Supreme Court case
Briefing
What it's about
True asked the Supreme Court to review whether his late federal petition should have been excused because of mental illness and limited access to legal materials, and whether he should have received a hearing on that issue. The materials provided show the case ended without a merits decision, leaving the Eighth Circuit's result in place.
Impact
This matters for prisoners who miss filing deadlines and say mental illness or prison conditions kept them from filing on time. For people in similar situations, the Supreme Court's refusal to take the case means no new nationwide rule came from this docket.
What's next
There is no further Supreme Court action in this docket. The Eighth Circuit result remains in place because the Court did not issue a merits decision here.
What was True v. Kelley about?
True asked the Court to review whether his federal filing was late. He said mental illness and limited access to legal materials should excuse the delay.
Who could be affected by True v. Kelley?
Prisoners who miss filing deadlines because of mental illness or poor access to legal help could watch cases like this closely. The Court's refusal to hear it left the lower-court result untouched.
What happens next in True v. Kelley?
Nothing further is scheduled at the Supreme Court in this docket. The Eighth Circuit outcome remains in place because review was not granted.
Decision
What the Court decided
The Supreme Court did not use this case to answer when mental illness or lack of legal materials can excuse a late filing.
Impact
This matters for prisoners who miss filing deadlines and say mental illness or prison conditions kept them from filing on time. For people in similar situations, the Supreme Court's refusal to take the case means no new nationwide rule came from this docket.
Not official Court text.
Timing
Decided April 27, 2020
The Court released its decision on April 27, 2020 without hearing oral argument.
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jul 25, 2026
- Method
- Methodology