Passalacqua v. McDonald
In brief
The Court refused to hear Passalacqua’s challenge, leaving the Ninth Circuit’s ruling in place without deciding the legal questions.
- Where it stands
- Decided
Decided · May 26, 2020
- What it’s about
- The Court denied review of Passalacqua’s challenge to the Ninth Circuit’s ruling, leaving that ruling in place.
- Who it affects
- The Ninth Circuit’s ruling remains in place for Passalacqua, but the Supreme Court’s order gave no answer to the issues he raised.
Summary: written with AI from the case record.
What it's about
The petition concerned whether a prisoner may use the actual-innocence exception to AEDPA’s one-year filing deadline to challenge a sentence, rather than the underlying conviction, and what a prisoner must show to qualify for that exception.
The dispute focused on whether the exception covers a sentence challenge and whether a prisoner must show legal innocence in addition to factual innocence.
Question presented
1. Whether the "actual innocence" exception to the AEDPA's one-year statute of limitations, as recognized in McQuiggin v. Perkins, 569 U.S. 383 (2013), applies to a petitioner who challenges his sentence rather than his underlying conviction? 2. Whether the Second Circuit's requirement that a petitioner show "legal innocence" as well as "factual innocence" to satisfy the McQuiggin standard is consistent with this Court's precedent?
What the Court decided
Holding
Petition DENIED.
What's next
The Supreme Court’s action is finished, and the Ninth Circuit’s ruling remains in place in this case.
Documents
Docket activity
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AI analysis generated: Case Briefing
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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.