Reed v. Goertz

In "REED v. GOERTZ," the U.S. Supreme Court addressed the timing for the statute of limitations in a §1983 procedural due process claim related to state post-conviction DNA testing. The Court held that the statute of limitations begins when state litigation ends, specifically when the Texas Court of Criminal Appeals denied Reed’s motion for rehearing, rather than when the Texas trial court initially denied the motion​​.

Introduction:
This case addresses procedural due process in the context of post-conviction DNA testing. The Supreme Court's decision clarifies when the statute of limitations starts for federal §1983 claims following state post-conviction proceedings.

Facts of the Case:
Rodney Reed was convicted in 1996 for the murder of Stacey Stites and sentenced to death. His conviction was affirmed by the Texas Court of Criminal Appeals. In 2014, Reed filed a motion for DNA testing of evidence under Texas’s post-conviction DNA testing law, arguing it would identify the true perpetrator. The state trial court and later the Texas Court of Criminal Appeals denied this motion, citing issues with the chain of custody and likelihood of acquittal based on the potential DNA results​​.

Issue of the Case:
The issue was whether Reed’s §1983 claim, challenging the constitutionality of Texas's post-conviction DNA testing law on procedural due process grounds, was filed within the appropriate statute of limitations period.

Ruling of the Case:
The Supreme Court held that the statute of limitations for Reed’s §1983 procedural due process claim began when the state litigation ended with the Texas Court of Criminal Appeals' denial of Reed’s motion for rehearing, not when the trial court initially denied the DNA testing motion. This ruling reversed the Fifth Circuit’s decision that the claim was filed too late​​.

Impact on the Legal System:
This decision impacts the timing of federal §1983 claims following state court decisions, particularly in cases involving post-conviction DNA testing. It ensures that defendants have adequate time to file federal claims after exhausting state court remedies, influencing the balance between state and federal court interactions in post-conviction processes.

Conclusion:
"REED v. GOERTZ" is significant for clarifying when federal claims related to state post-conviction DNA testing should be filed. It underscores the importance of procedural due process in the context of post-conviction relief and influences the interplay between state and federal courts in criminal justice proceedings.