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Reed v. Goertz

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Supreme Court of the United States
Reed v. Goertz
Term: 2022
Important Dates
Argued: October 11, 2022
Decided: April 19, 2023
Outcome
Reversed
Vote
6-3
Majority
Brett Kavanaugh • Chief Justice John Roberts • Sonia Sotomayor • Elena Kagan • Amy Coney Barrett • Ketanji Brown Jackson
Dissenting
Clarence Thomas • Samuel Alito • Neil Gorsuch

Reed v. Goertz is a case that was decided by the Supreme Court of the United States on April 19, 2023, during the court's October 2022-2023 term. The case was argued before the court on October 11, 2022.

The court reversed the decision of the U.S. Court of Appeals for the 5th Circuit in a 6-3 ruling, holding that the statute of limitations on post-conviction DNA testing begins when litigation ends. Justice Brett Kavanaugh delivered the majority opinion of the court. Justice Clarence Thomas filed a dissenting opinion. Justice Samuel Alito also filed a dissenting opinion, joined by Justice Neil Gorsuch.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: Rodney Reed was convicted of murdering Stacey Sites in 1998 based on DNA evidence. He was sentenced to death. In 2014, Reed filed an appeal in Texas state court for DNA testing. After his motion was denied, he continued to file appeals in the Texas judicial system. The courts denied his appeal each time. Reed then filed a lawsuit in federal court claiming that the Texas courts had violated his constitutional rights. The district court dismissed Reed's lawsuit. On appeal, the 5th Circuit affirmed the lower court's decision. Reed petitioned the U.S. Supreme Court for review.[2] Click here to learn more about the case's background.
  • The issue: The case concerned a split between the U.S. circuit courts on when the statute of limitations begins to run for a criminal defendant to file a federal claim for DNA testing of crime-scene evidence.
  • The question presented: "[W]hether the statute of limitations for a § 1983 claim seeking DNA testing of crime-scene evidence begins to run at the end of state court litigation denying DNA testing, including any appeals (as the Eleventh Circuit has held), or whether it begins to run at the moment the state trial court denies DNA testing, despite any subsequent appeal (as the Fifth Circuit, joining the Seventh Circuit, held below)."[3]
  • The outcome: On April 19, 2023, the court reversed the decision of the U.S. Court of Appeals for the 5th Circuit in a 6-3 ruling, holding that the statute of limitations on post-conviction DNA testing begins when litigation ends.


    • The case came on a writ of certiorari to the U.S. Court of Appeals for the 5th Circuit.

    Timeline

    The following timeline details key events in this case:

    Background

    In 1998, Rodney Reed, the petitioner, was convicted of murdering Stacey Sites. During the trial, the state argued that Reed was guilty because his DNA matched DNA found on the victim's body. Reed was sentenced to death.[2]

    In 2014, Reed moved in Texas state court for DNA testing under Texas’ Article 64. The trial court denied the motion. Reed continued to petition for DNA testing under Article 64, and was denied each time. In October 2019, Reed filed a lawsuit in federal court under 42 U.S.C. § 1983, claiming that the Texas courts' interpretation of Article 64 violated his constitutional rights. The U.S. District Court for the Western District of Texas dismissed Reed's suit. On appeal, the U.S. Court of Appeals for the 5th Circuit affirmed the district court's decision.[2]

    Reed petitioned the U.S. Supreme Court for review, arguing the 5th Circuit's decision "cements a circuit conflict over when the statute of limitations begins to run for a § 1983 claim seeking DNA testing."[2]

    42 U.S.C. § 1983

    Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.

    Question presented

    The petitioner presented the following question to the court:[3]

    Question presented:
    “ [W]hether the statute of limitations for a § 1983 claim seeking DNA testing of crime-scene evidence begins to run at the end of state court litigation denying DNA testing, including any appeals (as the Eleventh Circuit has held), or whether it begins to run at the moment the state trial court denies DNA testing, despite any subsequent appeal (as the Fifth Circuit, joining the Seventh Circuit, held below).[4] ”

    Oral argument

    Audio

    Audio of oral argument:[5]



    Transcript

    Transcript of oral argument:[6]

    Outcome

    In a 6-3 opinion, the court reversed the judgment of the United States Court of Appeals for the Fifth Circuit, holding that the statute of limitations on post-conviction DNA testing begins when litigation ends. Justice Brett Kavanaugh delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Brett Kavanaugh wrote:[1]

    “ 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.[4] ”
    —Justice Brett Kavanaugh

    Dissenting opinions

    Justice Thomas

    Justice Clarence Thomas filed a dissenting opinion.

    In his dissent, Justice Clarence Thomas wrote:[1]

    “

    Reed’s action should be dismissed for lack of subject-matter jurisdiction. Federal district courts lack appellate jurisdiction to review state-court judgments, and Reed’s action presents no original Article III case or controversy between him and the district attorney. [4]

    		”
    —Justice Clarence Thomas

    Justice Alito

    Justice Samuel Alito also filed a dissenting opinion, joined by Justice Neil Gorsuch.

    In his dissent, Justice Samuel Alito wrote:[1]

    “ [T]here is room for debate about exactly when Reed’s DNA testing claim accrued, but in my view, the notion that this did not take place until rehearing was denied is clearly wrong.[4] ”
    —Justice Samuel Alito

    Text of the opinion

    Read the full opinion here.

    October term 2022-2023

    See also: Supreme Court cases, October term 2022-2023

    The Supreme Court began hearing cases for the term on October 3, 2022. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[7]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 Supreme Court of the United States, ‘’Reed v. Goertz’’, decided April 19, 2023
    2. ↑ 2.0 2.1 2.2 2.3 Supreme Court of the United States, Reed v. Goertz - "Petition for a writ of certiorari," accessed April 25, 2022
    3. ↑ 3.0 3.1 Supreme Court of the United States, "'REED v. GOERTZ - PETITION FOR A WRIT OF CERTIORARI," accessed April 25, 2022
    4. ↑ 4.0 4.1 4.2 4.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 11, 2022
    6. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 11, 2022
    7. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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