SCOTUS Sides With Death Row Inmate in DNA-Testing Case
In Reed v. Goertz,598 U.S. ____ (2023), the U.S. Supreme Court held that death row inmate Rodney Reed did not wait too long to seek DNA testing of the evidence in his case. According to the Court majority, when a prisoner pursues state post-conviction DNA testing through the state-provided litigation process, the statute of limitations for a 42 U.S.C. § 1983 procedural due process claim begins to run at the end of the state-court litigation.
Facts of the Case
A Texas jury found petitioner Rodney Reed guilty of the 1996 murder of Stacey Stites. The Texas Court of Criminal Appeals affirmed Reed’s conviction and death sentence. In 2014, Reed filed a motion in Texas state court under Texas’s post-conviction DNA testing law. Reed re- quested DNA testing on certain evidence, including the belt used to strangle Stites, which Reed contended would help identify the true perpetrator. The state trial court denied Reed’s motion, reasoning in part that items Reed sought to test were not preserved through an adequate chain of custody. The Texas Court of Criminal Appeals affirmed, and later denied Reed’s motion for rehearing. Reed then sued in federal court under 42 U.S.C. §1983, asserting that Texas’s post-conviction DNA testing law failed to provide procedural due process. Reed argued that the law’s stringent chain-of-custody requirement was unconstitutional.
The District Court dismissed Reed’s complaint. The Fifth Circuit Court of Appeals affirmed on the ground that Reed’s §1983 claim was filed too late, after the applicable two-year statute of limitations had run. According to the Fifth Circuit, 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.
Supreme Court’s Decision
The Supreme Court reversed by a vote of 6-3. It held that 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, the clock started when the Texas Court of Criminal Appeals denied Reed’s motion for rehearing. Justice Brett Kavanaugh wrote on behalf of the majority.
The Court first addressed Texas’ threshold arguments, which included that Reed lacked standing. In rejecting the argument, Justice Kavanaugh explained that Reed sufficiently alleged an injury in fact: denial of access to the requested evidence. Additionally, the state prosecutor, who is the named defendant, denied access to the evidence and thereby caused Reed’s injury. Further, a federal court conclusion that Texas’s post-conviction DNA testing procedures denied Reed due process would “amount to a significant increase in the likelihood” that Reed “would obtain relief that directly redresses the injury suffered.”
The Court next turned to the key issue — when the clock on the two-year statute of limitations began to run. Justice Kavanaugh first noted that, as a general matter, the statute of limitations begins to run when the plaintiff has a “complete and present cause of action.” To determine when a plaintiff has a complete and present cause of action, the Court focuses first on the specific constitutional right alleged to have been infringed.
In this case, the specific constitutional right allegedly infringed was procedural due process. A procedural due process claim consists of two elements: (i) deprivation by state action of a protected interest in life, liberty, or property, and (ii) inadequate state process. As relevant to Reed’s case, the Court has stated that a procedural due process claim “is not complete when the deprivation occurs,” but rather when “the State fails to provide due process.” Zinermon v. Burch, 494 U.S. 113, 125 (1990).
“In Reed’s case, the State’s alleged failure to provide Reed with a fundamentally fair process was complete when the state litigation ended and deprived Reed of his asserted liberty interest in DNA testing,” Justice Kavanaugh wrote. “Therefore, Reed’s §1983 claim was complete and the statute of limitations began to run when the state litigation ended—when the Texas Court of Criminal Appeals denied Reed’s motion for rehearing.”
According to the majority, the “soundness” of that straightforward conclusion is “reinforced by the consequences that would follow” from a contrary approach. As Justice Kavanaugh explained:
If the statute of limitations for a §1983 suit like Reed’s began to run after a state trial court’s denial of a plaintiff ’s motion for DNA testing (or even after the appeal before the plaintiff ’s rehearing proceedings), the plaintiff would likely continue to pursue relief in the state system and simultaneously file a protective federal §1983 suit challenging that ongoing state process. That parallel litigation would “run counter to core principles of federalism, comity, consistency, and judicial economy.”
Justice Kavanaugh added that “significant systemic benefits” ensue from starting the statute of limitations clock when the state litigation in DNA testing cases like Reed’s has concluded. “If any due process flaws lurk in the DNA testing law, the state appellate process may cure those flaws, thereby rendering a federal §1983 suit unnecessary,” he wrote. “And if the state appellate court construes the DNA testing statute, that construction will streamline and focus subsequent §1983 proceedings.”
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Congress of the United States begun and held at the City of New-York, on Wednesday the fourth of March, one thousand seven hundred and eighty nine.
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