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No. 21-442October Term 2022Decided Apr 19, 2023

Docket 21-442October Term 2022 (2022–2023)

Reed v. Goertz

Reed won: the federal filing deadline began after Texas's state-court DNA-testing litigation was fully over, not when the trial court first denied testing.

Case status

Current stage
Decided
Latest event
Decision released Apr 19, 2023
Case Accepted
Arguments HeardOct 11, 2022
Decision ReleasedApr 19, 2023
What it's about

Rodney Reed, a death row inmate, filed a federal civil rights lawsuit seeking DNA testing of crime-scene evidence after state courts denied his request. The Supreme Court decided that the statute of limitations for such a lawsuit begins to run when the state-court litigation, including any appeals, officially ends.

Question presented

Whether the statute of limitations for a 42 U.S.C. § 1983 claim challenging a state’s post-conviction DNA testing procedures begins to run when the state trial court denies the DNA testing, or only when the state appellate litigation is complete?

Case path

United States Court of Appeals for the Fifth Circuit / Decision released Apr 19, 2023

Area

Civil Rights

Briefing

What it's about

The Court ruled that the deadline for a federal civil-rights lawsuit challenging state DNA-testing procedures starts after the state's full review process ends, including appeals. For Rodney Reed, that date was when the Texas Court of Criminal Appeals denied rehearing.

Vote

The Court ruled 6-3. Justice Brett M. Kavanaugh wrote the majority opinion, joined by Chief Justice John G. Roberts, Jr., and Justices Sonia Sotomayor, Elena Kagan, Amy Coney Barrett, and Ketanji Brown Jackson. Justice Clarence Thomas dissented, and Justices Samuel A. Alito, Jr., and Neil Gorsuch also dissented; Alito wrote a dissent.

The statute of limitations begins to run when the state litigation ends.

Justice Brett M. Kavanaugh(majority)

Impact

Prisoners seeking post-conviction DNA testing can finish the state appeal process before the federal lawsuit deadline begins. For example, a person whose trial-court request is denied can appeal in state court without losing time to file a federal challenge.

What's next

Lower courts must apply this timing rule to similar federal challenges to state DNA-testing procedures. Reed's case returns to proceed under the Court's ruling that his claim was filed on time.

What did the Supreme Court rule in Reed v. Goertz?

The Court said the filing deadline starts when state-court DNA-testing litigation ends, including appeals. It does not start with the trial court's first denial.

Who is affected by Reed v. Goertz?

Prisoners challenging state post-conviction DNA-testing procedures in federal court are affected. They can complete state appeals before the federal deadline begins.

What happens next in Reed v. Goertz?

Lower courts must use the Supreme Court's timing rule in similar cases. Reed's lawsuit can continue under that rule.

Decision

Decision record

What the Court decided

Reed won: the federal filing deadline began after Texas's state-court DNA-testing litigation was fully over, not when the trial court first denied testing.

Impact

Prisoners seeking post-conviction DNA testing through state procedures are affected. Their statute of limitations (deadline to sue) for a federal civil-rights claim starts when state litigation ends. For Reed, it started when the Texas Court of Criminal Appeals denied rehearing, not at the trial court denial. This gives prisoners time to complete state appeals before the federal deadline starts. The Court reversed the Fifth Circuit’s conclusion that Reed’s claim was untimely.

Not official Court text.

Timing

Decided April 19, 2023

The Court released its decision 190 days after oral argument on October 11, 2022. The median for cases argued in October is 139 days.

Based on 36 merits cases argued in October since 1995.Argument and decision days