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No. 20-1704October Term 2020Decided Nov 1, 2021Updated Nov 1, 2021

Docket 20-1704October Term 2020 (2020–2021)

Simmons v. United States

This case asks when a federal court may throw out a prisoner's late habeas petition under AEDPA without a hearing.

Case status

Decided · November 1, 2021

Read the opinion (PDF)
Current stage
Decided
Latest event
Decision released Nov 1, 2021
Case Accepted
Arguments
Decision ReleasedNov 1, 2021
What it's about

This case asks when a federal court may throw out a prisoner's late habeas petition under AEDPA without a hearing. Simmons says the government created an unlawful obstacle that kept him from filing on time, and the issue is whether a court can reject that claim at the pleading stage because a pro se prisoner did not describe the causal link in enough detail.

Question presented

Whether a court can summarily dismiss a pro se habeas petition as untimely for failure to adequately allege a causal connection when petitioner explains how a government impediment “prevented” him from filing timely, but does not allege with specificity how he discovered and attempted to remedy that impediment?

Case path

United States Court of Appeals for the Sixth Circuit / Decision released Nov 1, 2021

Area

Criminal Procedure

Timing

Decided November 1, 2021

The Court released its decision on November 1, 2021 without hearing oral argument.

Activity

Docket activity2
  • Opinion added: Opinion

    Nov 1, 2021 | Court records

  • Brief added: Petition

    Jun 4, 2021 | Court records

Grounding

Grounding
Primary-source trail available.
Note
Plain-English explainer. Official filings and opinions remain authoritative.
Checked
Jul 25, 2026
Primary materials5