Day v. McDonough, 547 U.S. 198 (2006)
Primary Holding
A 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.
In the case of Day v. McDonough, a man named Patrick Day was trying to challenge his prison sentence, but his request was dismissed because it was deemed too late, even though the state initially said it was on time. This ruling matters because it shows that federal courts can decide to reject a prisoner's appeal based on timing, even if the state agrees it was filed on time. This case is relevant for anyone in a similar situation, as it highlights the importance of filing legal requests within strict deadlines, and that even state agreements can be challenged if there’s a mistake in the timing calculations.
AI-generated plain-language summary to help you understand this case
In Day v. McDonough, 547 U.S. 198 (2006), Patrick A. Day was convicted of second-degree murder and sentenced to 55 years in prison by a Florida trial court. After his conviction was affirmed on December 21, 1999, Day did not seek review from the U.S. Supreme Court, and the time for doing so expired on March 20, 2000. Nearly a year later, on March 7, 2001, Day filed for state postconviction relief, which was ultimately denied. He did not appeal this denial, and the time for filing a federal habeas corpus petition began to run. The procedural history of the case began when Day filed a federal habeas corpus petition. The State of Florida, in its response, conceded that the petition was timely, stating it was filed after 352 days of untolled time. However, a Federal Magistrate Judge reviewed the case and determined that the State had miscalculated the tolling period, concluding that the petition was actually untimely by 388 days. After giving Day an opportunity to explain why the petition should not be dismissed, the Magistrate Judge recommended dismissal, which the District Court adopted. The Eleventh Circuit Court of Appeals affirmed this decision, stating that a federal court could dismiss a habeas petition as untimely even if the State had erroneously conceded its timeliness. The relevant background context includes the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), which imposes a one-year limitation period for filing federal habeas corpus petitions. This period is tolled while a "properly filed" application for state postconviction relief is pending, but does not include the 90 days during which a petitioner could seek certiorari review in the U.S. Supreme Court. The case raised the question of whether a federal court has the authority to dismiss a habeas petition as untimely on its own initiative, despite the State's concession of timeliness, highlighting the tension between state and federal procedural rules.
Whether a federal court lacks authority, on its own initiative, to dismiss a habeas petition as untimely, once the State has answered the petition without contesting its timeliness.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- February 27, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- 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.
Mayle v. Felix, 545 U.S. 644 (2005)
Consumer LostAn amended habeas petition does not relate back to the date of the original petition under Federal Rule of Civil Procedure 15(c)(2) when it asserts a new ground for relief that is supported by facts differing in both time and type from those in the original pleading, thereby not escaping the one-year limitation period imposed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
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.
Gonzalez v. Crosby, 545 U.S. 524 (2005)
Consumer LostA motion for relief from a judgment in a habeas corpus case, filed under Federal Rule of Civil Procedure 60(b), is subject to the restrictions that apply to “second or successive” habeas corpus petitions under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).