- Court: United States Supreme Court
- Area(s) of Law:
- Date Filed: April 19, 2023
- Case #: 21-442
- Judge(s)/Court Below: Kavanaugh, J., delivered the opinion of the Court, in which Roberts, C. J., and Sotomayor, Kagan, Barrett, and Jackson, JJ., joined. Thomas, J., filed a dissenting opinion, post, p. 237. Alito, J., filed a dissenting opinion, in which Gorsuch, J., joined.
- Full Text Opinion
Plaintiff appealed a federal district court’s dismissal of his 42 U.S. C § 1983 claim that “Texas’ post-conviction DNA testing law failed to provide procedural due process.” Plaintiff assigned error to the Fifth Circuit’s holding that the two year statute of limitations began to run when the Texas trial court denied Plaintiff’s motion, rendering his appeal untimely. In a procedural due process claim, the plaintiff has a complete and present claim when “the state fails to provide due process,” not when the deprivation occurs. Zinermon v. Burch, 494 U.S. 113, 125 (1990). The Court reasoned that, if the statute of limitations began to run after the state trial court’s denial of a DNA testing motion, the plaintiff would simultaneously pursue relief in state and federal court, resulting in “senseless duplication.” The Court further reasoned that, if the statute of limitations began to run when the state litigation concluded, the state appellate process could clear any due process flaws. Thus, when a prisoner pursues post-conviction DNA testing, “the statute of limitations for a §1983 procedural due process claim begins to run when the state litigation ends.” Here, it began to run when the Texas Appeal’s Court denied Plaintiff’s rehearing motion. REVERSED.