Reed v. Goertz
In brief
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.
- Where it stands
- Decided
Decided 6-3 · April 19, 2023 · Opinion by Justice Kavanaugh
- 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.
- Who it affects
- 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.
Summary: written with AI from the case record.
What it's about
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.
The decision resolves a split among federal appeals courts over when the clock starts for these DNA-testing claims.
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?
What the Court decided
The vote
From the opinions
“The statute of limitations begins to run when the state litigation ends.”
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.
Documents
Docket activity
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AI analysis generated: Impact Analysis
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AI analysis generated: Case Briefing
AI analysis generated: Opinion Summary
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More questions
- 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.
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.