Allen v. Siebert, 552 U.S. 3 (2007)
Primary Holding
A state postconviction petition rejected by the state court as untimely is not considered "properly filed" under 28 U.S.C. § 2244(d)(2), and thus does not toll the one-year statute of limitations for filing a federal habeas petition.
In the case of Allen v. Siebert, the Supreme Court ruled that if a person files a state petition for postconviction relief (asking to challenge their conviction) but it gets rejected because it was late, that petition doesn't count as "properly filed." This matters because it means that if someone misses the deadline for state appeals, they can't extend the time to file a federal appeal, which could prevent them from getting a fair chance to challenge their conviction. This ruling protects consumers by clarifying that strict deadlines must be followed in the legal process, emphasizing the importance of timely action when seeking legal remedies. If someone is in a similar situation, like trying to appeal a conviction, this case highlights the need to be aware of and meet all deadlines to preserve their rights.
AI-generated plain-language summary to help you understand this case
In the case of Allen v. Siebert, 552 U.S. 3 (2007), Daniel Siebert was convicted of murdering Linda Jarman in Alabama and sentenced to death. His conviction was affirmed on direct appeal, with the certificate of judgment issued on May 22, 1990. After the U.S. Supreme Court denied certiorari on November 5, 1990, Siebert filed a petition for postconviction relief in Alabama state court on August 25, 1992. However, the state courts denied his petition as untimely, as it was filed approximately three months after the expiration of the two-year statute of limitations. The Alabama Supreme Court subsequently denied certiorari on September 15, 2000, and Siebert did not seek further review. Siebert then filed a federal habeas corpus petition in the District Court for the Northern District of Alabama on September 14, 2001. Under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a one-year statute of limitations for filing federal habeas petitions was established, which began to run from April 24, 1996, since Siebert's direct appeal had concluded before AEDPA took effect. The District Court dismissed Siebert's habeas petition as untimely, reasoning that his state postconviction relief application was not "properly filed" due to its rejection on statute-of-limitations grounds. However, the Court of Appeals reversed this decision, asserting that the state time bar was not jurisdictional, thus allowing for discretion in its enforcement. While Siebert's case was pending, the Supreme Court decided Pace v. DiGuglielmo, which held that a state postconviction petition rejected as untimely is not "properly filed" under AEDPA. Relying on this decision, the District Court dismissed Siebert's petition again as untimely. The Court of Appeals, however, reversed once more, distinguishing Siebert's case from Pace by stating that Alabama's statute of limitations operated as an affirmative defense rather than a jurisdictional barrier. This led to a complex procedural history that ultimately resulted in the Supreme Court's review of the case.
Whether a state postconviction petition rejected by the state court as untimely is considered "properly filed" within the meaning of 28 U.S.C. §2244(d)(2) for the purposes of tolling the one-year statute of limitations for federal habeas corpus petitions.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 5, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Pace v. DiGuglielmo, 544 U.S. 408 (2005)
Consumer LostA state postconviction petition rejected by the state court as untimely is not considered "properly filed" under the federal Antiterrorism and Effective Death Penalty Act's tolling provision, and therefore does not toll the one-year statute of limitations for filing a federal habeas corpus petition.
Day v. McDonough, 547 U.S. 198 (2006)
Consumer LostA federal court has the discretion to dismiss a state prisoner's habeas corpus petition as untimely, even if the state has conceded its timeliness, when the state has made an evident miscalculation of the elapsed time under the Antiterrorism and Effective Death Penalty Act's one-year limitation period.
Lawrence v. Florida, 549 U.S. 327 (2007)
Consumer LostA state application for post-conviction relief is not considered "pending" for the purposes of tolling the one-year statute of limitations for federal habeas corpus relief once the state courts have entered a final judgment on the matter, even if a petition for certiorari has been filed in the Supreme Court.
Evans v. Chavis, 546 U.S. 189 (2006)
Consumer LostThe time that an application for state postconviction review is “pending” under the Antiterrorism and Effective Death Penalty Act includes the period between a lower court’s adverse determination and the timely filing of a notice of appeal, even in states like California where the appeal process allows for a filing within a "reasonable time.