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Reed v. Goertz

Supreme Court of the United States
598 U. S. ____ (2023) (2023)
ELI5:

Rule of Law:

When a prisoner brings a § 1983 procedural due process claim challenging a state’s post-conviction DNA testing procedures, the statute of limitations begins to run only when the state litigation process concludes, including all appellate review and motions for rehearing.


Facts:

  • In 1996, Stacey Stites was strangled to death in Bastrop County, Texas, with her own belt.
  • Rodney Reed was charged with her murder.
  • At his trial, Reed maintained his innocence, claiming he and Stites were having a consensual affair and that her fiancé was the likely killer.
  • A Texas jury found Reed guilty of murder and sentenced him to death.
  • In 2014, Reed sought post-conviction DNA testing under Texas law on more than 40 items of evidence, including the belt used to strangle Stites.
  • Reed contended that such testing would help identify the true perpetrator.
  • The state prosecutor, Bryan Goertz, opposed testing most of the requested items.

Procedural Posture:

  • In 2014, Rodney Reed filed a motion in a Texas state trial court seeking post-conviction DNA testing.
  • The state trial court denied Reed’s motion.
  • Reed appealed to the Texas Court of Criminal Appeals, the state's highest court for criminal matters.
  • The Texas Court of Criminal Appeals affirmed the trial court's denial.
  • The Texas Court of Criminal Appeals then denied Reed's motion for rehearing.
  • Reed filed a lawsuit under 42 U.S.C. § 1983 against prosecutor Bryan Goertz in the U.S. District Court for the Western District of Texas.
  • The District Court dismissed Reed’s complaint.
  • Reed, as appellant, appealed to the U.S. Court of Appeals for the Fifth Circuit, with Goertz as appellee.
  • The Fifth Circuit affirmed the dismissal, holding that the two-year statute of limitations began to run when the state trial court denied the motion, making Reed's federal lawsuit untimely.
  • The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.

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Issue:

Does the statute of limitations for a prisoner's § 1983 procedural due process claim, which challenges a state's post-conviction DNA testing procedures, begin to run when the state litigation process concludes, including appellate review and motions for rehearing?


Opinions:

Majority - Justice Kavanaugh

Yes, the statute of limitations for a § 1983 procedural due process claim begins to run when the state litigation ends. A procedural due process claim is not complete when the deprivation occurs, but only when the state fails to provide due process. Texas's process for considering a DNA testing request includes not only trial court proceedings but also appellate review by the Court of Criminal Appeals, which encompasses a motion for rehearing. Therefore, the State’s alleged failure to provide a fair process was not complete, and Reed's cause of action did not accrue, until the Texas Court of Criminal Appeals denied his motion for rehearing. This rule avoids premature and parallel federal litigation, promoting federalism, comity, and judicial economy by allowing state appellate courts to potentially cure any procedural flaws before a federal suit is necessary.


Dissenting - Justice Thomas

The Court should not reach the statute of limitations issue because the federal district court lacks subject-matter jurisdiction. Reed's lawsuit is an improper attempt to obtain appellate review of a state-court judgment in a federal district court, which is barred by the Rooker-Feldman doctrine. The alleged injury was inflicted by the Texas Court of Criminal Appeals' decision, not by any conduct of the prosecutor, Bryan Goertz. Therefore, there is no original Article III case or controversy between Reed and Goertz. Reed’s complaint transparently seeks a 'review and rejection' of the state court's judgment, which is a form of appellate jurisdiction that district courts do not possess.


Dissenting - Justice Alito

No, the statute of limitations began to run before the state court denied rehearing. The claim accrued, at the latest, when the Texas Court of Criminal Appeals (CCA) issued its decision interpreting the state DNA testing statute, not when it later denied a petition for rehearing. An appellate court's decision is authoritative when it is handed down; its force is not suspended pending a rehearing motion. The majority's 'end of litigation' reasoning collides with the established principle that § 1983 plaintiffs are not required to exhaust state remedies. Reed provided no reason why he could not have filed his federal suit within two years of the CCA's decision.



Analysis:

This decision resolves a circuit split and establishes a clear, bright-line rule for the accrual of procedural due process claims related to state post-conviction DNA testing laws. By tying the start of the limitations period to the absolute conclusion of state proceedings, the Court prioritizes federalism and judicial efficiency, allowing state courts the final word before federal intervention. This ruling provides prisoners with a definitive end-point to state litigation, clarifying when they must file in federal court, and discourages parallel state and federal lawsuits over the same procedural issue.

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