Reed v. Goertz, 598 U.S. 230 (2023), is a United States Supreme Court case regarding the statute of limitations for a Section 1983 claim.
| Reed v. Goertz | |
|---|---|
 | |
| Argued October 11, 2022 Decided April 19, 2023 | |
| Full case name | Reed v. Goertz |
| Docket no. | 21-442 |
| Citations | 598 U.S. 230 (more) |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | United States Court of Appeals, Fifth Circuit No. 19-70022 |
| Questions presented | |
| Did the statute of limitations begin to run when Reed's motion was denied or when the Texas Court of Criminal Appeals denied to rehear the trial? | |
| Holding | |
| When a prisoner pursues state post-conviction DNA testing through the state-provided litigation process, the statute of limitations for a §1983 procedural due process claim begins to run when the state litigation ends, in this case when the Texas Court of Criminal Appeals denied Reed’s motion for rehearing. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Kavanaugh, joined by Roberts, Sotomayor, Kagan, Barrett, Jackson |
| Dissent | Thomas |
| Dissent | Alito, joined by Gorsuch |
| Laws applied | |
| US Constitutional Amendment V, 42 U.S. Code § 1983 | |
Background
editA Texas jury found Rodney Reed guilty of the murder of Stacey Stites.[1] During the penalty phase several women testified that Reed had raped and assaulted them.[2][3] He was sentenced to death. In 2014, Reed filed a motion in Texas state court under the state's post-conviction DNA testing law. He requested DNA testing on certain pieces of evidence, including the belt used to strangle Stites. The state court denied Reed's motion, reasoning that the items Reed requested to be tested were not preserved through an adequate chain of custody. The Texas Court of Criminal Appeals agreed and denied Reed's motion for a rehearing. Reed then sued in federal court under 42 U.S. Code §1983, a federal law allowing citizens to sue state officials for violating their federally protected rights,[4] claiming that Texas's post-conviction DNA testing law failed to provide procedural due process. Reed also argued that the law's strict chain of custody requirements was unconstitutional. The District Court dismissed his complaint while The Fifth Circuit affirmed on the ground that Reed’s §1983 claim was filed too late, after the applicable 2-year statute of limitations had run. The Fifth Circuit held that the limitations period began to run when the Texas trial court denied Reed’s motion, not when the Texas Court of Criminal Appeals denied rehearing.[5][6]
Supreme Court decision
editReed sought review of the Fifth Circuit decision by the Supreme Court and filed a writ of certiorari.[7] The Supreme Court decided 6-3 that the limitations began when state litigation ended, which was when the Texas Court of Criminal Appeals denied Reed's motion for rehearing on the DNA testing claim, reversing the Fifth Circuit's decision.[8] It is unclear when Reed's execution will occur.[7]
References
edit- ^ Asgarian, Roxanna (2023-04-19). "U.S. Supreme Court lets Texas death row inmate Rodney Reed pursue DNA testing in bid to prove innocence". The Texas Tribune. Retrieved 2024-06-23.
- ^ Reed v. Goertz, Thomas dissenting
- ^ "Many in Bastrop Moved on From the Rodney Reed Trial. One Juror Couldn't". TexasMonthly. March 27, 2024.
- ^ "Determining When A Statute Creates a Federal Right Actionable under 42 U.S.C. § 1983". Congressional Research Service.
- ^ United States, U.S. Supreme Court (U.S.). Reed v. Goertz. United States Reports, vol. 598, 19 Apr. 2023. Supreme Court, www.supremecourt.gov/opinions/22pdf/21-442_e1p3.pdf. Accessed 23 June 2024.
- ^ United States, Fifth Circuit Court (5th Cir.). Reed v. Goertz. United States Reports, vol. __, 22 Apr. 2021. FindLaw, caselaw.findlaw.com/court/us-5th-circuit/2123999.html. Accessed 26 June 2024.
- ^ a b Barer, David (2024-03-06). "Pending proceedings could reshape Rodney Reed death row case". KXAN Austin. Retrieved 2024-06-26.
- ^ "Reed v. Goertz." Oyez, www.oyez.org/cases/2022/21-442. Accessed 23 Jun. 2024.
Further reading
edit- "Not Just Rodney Reed: New Evidence Taints More Death Row Convictions". The New York Times. November 19, 2019.
External links
edit- Text of Reed v. Goertz, 598 U.S. 230 (2023) is available from: Cornell Justia Oyez (oral argument audio) Supreme Court (preliminary print)