Reed v. Goertz

Reed v. Goertz
Supreme Court of the United States
Argued October 11, 2022 Decided April 19, 2023
Full case name	Reed v. Goertz
Docket no.	21-442
Citations	598 U.S. 230 (more)
Argument	Oral argument
Opinion announcement	Opinion announcement
Case history
Prior	United States Court of Appeals, Fifth Circuit No. 19-70022
Questions presented
Did the statute of limitations begin to run when Reed's motion was denied or when the Texas Court of Criminal Appeals denied to rehear the trial?
Holding
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.
Court membership
Chief Justice John Roberts Associate Justices Clarence Thomas · Samuel Alito Sonia Sotomayor · Elena Kagan Neil Gorsuch · Brett Kavanaugh Amy Coney Barrett · Ketanji Brown Jackson
Case opinions
Majority	Kavanaugh, joined by Roberts, Sotomayor, Kagan, Barrett, Jackson
Dissent	Thomas
Dissent	Alito, joined by Gorsuch
Laws applied
US Constitutional Amendment V, 42 U.S. Code § 1983

Reed v. Goertz, 598 U.S. 230 (2023), is a United States Supreme Court case regarding the statute of limitations for a Section 1983 claim.

A Texas jury found Rodney Reed guilty of the murder of Stacey Stites.^[1] During the penalty phase several women testified that Reed had raped and assaulted them.^[2][3] He was sentenced to death. In 2014, Reed filed a motion in Texas state court under the state's post-conviction DNA testing law. He requested DNA testing on certain pieces of evidence, including the belt used to strangle Stites. The state court denied Reed's motion, reasoning that the items Reed requested to be tested were not preserved through an adequate chain of custody. The Texas Court of Criminal Appeals agreed and denied Reed's motion for a rehearing. Reed then sued in federal court under 42 U.S. Code §1983, a federal law allowing citizens to sue state officials for violating their federally protected rights,^[4] claiming that Texas's post-conviction DNA testing law failed to provide procedural due process. Reed also argued that the law's strict chain of custody requirements was unconstitutional. The District Court dismissed his complaint while The Fifth Circuit affirmed on the ground that Reed’s §1983 claim was filed too late, after the applicable 2-year statute of limitations had run. The Fifth Circuit held that 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.^[5][6]

Reed sought review of the Fifth Circuit decision by the Supreme Court and filed a writ of certiorari.^[7] The Supreme Court decided 6-3 that the limitations began when state litigation ended, which was when the Texas Court of Criminal Appeals denied Reed's motion for rehearing on the DNA testing claim, reversing the Fifth Circuit's decision.^[8] It is unclear when Reed's execution will occur.^[7]

• "Not Just Rodney Reed: New Evidence Taints More Death Row Convictions". The New York Times. November 19, 2019.

• Text of Reed v. Goertz, 598 U.S. ___ (2023) is available from: Cornell Justia Oyez (oral argument audio) Supreme Court (preliminary print)