Reed v. Goertz
Issues
Does the statute of limitations for a federal law allowing prisoners the right to challenge a state’s post-conviction DNA testing regime begin to run as soon as the state trial court denies DNA testing or at the end of the state-court litigation, including all appeals?
This case asks the Supreme Court to resolve a circuit split and decide when the statute of limitations for 42 U.S.C. § 1983 claims for post-conviction DNA testing begin to run. Rodney Reed argues that the statute of limitations for his § 1983 claim for DNA testing should begin after the Texas Court of Criminal Appeals denied rehearing because this is the point at which he exhausted his state court options. Bryan Goertz counters that the statute of limitations should begin after the trial court denied Reed’s DNA testing request because this is when Reed first became aware that his right to DNA testing was allegedly being violated. The outcome of this case has significant implications for federalism, inmate rights, and the accuracy of the justice system.
Questions as Framed for the Court by the Parties
Whether the statute of limitations for a 42 U.S.C. § 1983 claim seeking DNA testing of crime-scene evidence begins to run at the end of state-court litigation denying DNA testing, including any appeals (as the U.S. Court of Appeals for the 11th Circuit has held), or whether it begins to run at the moment the state trial court denies DNA testing, despite any subsequent appeal (as the U.S. Court of Appeals for the 5th Circuit, joining the U.S. Court of Appeals for the 7th Circuit, held below).
In 1996, 19-year-old Stacey Stites’ body was found on the side of a country road in Bastrop County, Texas. Reed v. Goertz, at 2. The medical examiner determined that Stites was strangled to death with her belt. Id.
Additional Resources
- Jesus Jiménez, Supreme Court to Hear DNA Appeal in Rodney Reed Murder Case, New York Times (Apr. 25, 2022).
- Jordan Rubin, Justices Take on DNA-Testing Appeal Timing in Innocence Case, Bloomberg Law (Apr. 25, 2022).
- Dan Schweitzer, Supreme Court Report: Reed v. Goertz, 21-442, National Association of Attorneys General (May 19, 2022).