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Artuz v. Bennett

United States Supreme Court
531 U.S. 4 (2000)
ELI5:

Rule of Law:

An application for state post-conviction relief is considered 'properly filed' under 28 U.S.C. § 2244(d)(2) if it conforms to the state's formal filing requirements, such as rules regarding the form of the document, time limits, and place of filing, regardless of whether the substantive claims within the application are procedurally barred under state law.


Facts:

  • In 1984, a jury in New York state court convicted respondent Bennett of several crimes, including attempted murder.
  • Following his conviction, Bennett's direct appeals were affirmed by the state appellate court, and the highest state court denied further review.
  • Bennett unsuccessfully pursued state post-conviction relief in 1991.
  • In 1995, Bennett filed a pro se motion in state court to vacate his judgment of conviction.
  • The claims in Bennett's 1995 motion were subject to dismissal under New York's procedural rules, which bar claims that were previously determined on the merits on appeal or that could have been raised on direct appeal but were not.
  • The state trial court denied Bennett's 1995 motion in an oral decision, but Bennett claimed he never received a written order of the denial.

Procedural Posture:

  • Bennett filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of New York.
  • The District Court dismissed the petition as untimely under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
  • Bennett, as appellant, appealed the dismissal to the U.S. Court of Appeals for the Second Circuit.
  • The Second Circuit, with Artuz as appellee, reversed the District Court's decision, holding that the one-year limitations period was tolled because Bennett's state post-conviction motion was 'properly filed' and still 'pending'.
  • The U.S. Supreme Court granted certiorari to resolve the question of what constitutes a 'properly filed' application.

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Issue:

Is a state post-conviction relief application considered 'properly filed' for purposes of tolling the Antiterrorism and Effective Death Penalty Act's (AEDPA) statute of limitations under 28 U.S.C. § 2244(d)(2) if it meets the state's formal filing requirements, even if the claims it contains are subject to dismissal under state procedural bars?


Opinions:

Majority - Justice Scalia

Yes. A state post-conviction relief application is 'properly filed' if it adheres to the state’s formal filing requirements, even if the underlying claims are procedurally barred. The Court reasoned that the ordinary meaning of 'properly filed' relates to the formal conditions of filing, such as the form of the document, timeliness, and submission to the correct court, not to the substantive merits or procedural viability of the claims asserted within the application. The Court distinguished between an 'application,' which is filed, and a 'claim,' which is procedurally defaulted. Since the statute refers to a 'properly filed application,' the inquiry is limited to whether the application as a whole was submitted in compliance with the rules governing filings. To hold otherwise would conflate the distinct concepts of filing an application and presenting a valid claim, and would require federal courts to make complicated determinations of state procedural law simply to resolve a timeliness issue.



Analysis:

This decision provides a clear, bright-line rule for interpreting AEDPA's tolling provision, favoring a textualist and formalistic approach over a substantive one. By defining 'properly filed' based on compliance with formal filing rules, the Court simplifies the threshold inquiry for federal courts and provides greater certainty for prisoners seeking to exhaust state remedies. This holding prevents federal courts from engaging in premature and complex analyses of state procedural default rules when determining the timeliness of a habeas petition, thereby promoting judicial efficiency while ensuring that the tolling provision is not unduly narrowed.

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