Reed v. Goertz, 598 U.S. ___ (2023), is a United States Supreme Court case regarding the statute of limitations.
| 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. ___ (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 | |
| The statute of limitations, a procedural due process claim under 42 U.S.C. § 1983, begins to run when the state litigation ends. | |
| 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] 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 U.S. Code allowing citizens to sue state officials for violating civil rights[2], 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.[3][4]
Supreme Court decision
editReed sought review of the Fifth Circuit decision by the Supreme Court and filed a writ of certiorari.[5] 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.[6] It is unclear when Reed's execution will occur.[5]
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.
- ^ Hannon, Mike. "Research Guides: Civil Rights in the United States: Section 1983 (42 U.S.C. § 1983 - Civil action for deprivation of rights) & Bivens Actions". libguides.law.umn.edu. Retrieved 2024-06-26.
- ^ 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.
External links
edit- Text of Reed v. Goertz, 598 U.S. ___ (2023) is available from: Cornell Justia Oyez (oral argument audio) Supreme Court (preliminary print)