Evans v. Chavis, 546 U.S. 189 (2006)
Primary Holding
The 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.
In the case of Evans v. Chavis, the Supreme Court decided that the time a prisoner has to appeal a negative decision from a lower court counts as part of the time they can seek federal help with their case. This matters because it gives prisoners more time to file their appeals without losing their chance to challenge their convictions. This case is relevant for anyone in a similar situation, as it clarifies that even if a state allows for a "reasonable time" to appeal, the time still counts toward their deadline for seeking federal review.
AI-generated plain-language summary to help you understand this case
In Evans v. Chavis, the underlying dispute arose from a California prisoner's attempt to seek federal habeas corpus relief after his state conviction became final. Reginald Chavis, the respondent, had his state habeas application denied by a lower court, and he subsequently filed a request for appellate review three years later. The central issue was whether this request was timely under California's unique system, which allows for appeals to be filed within a "reasonable time" rather than a fixed period, as is common in most states. The procedural history of the case involved the Ninth Circuit Court of Appeals, which ruled that Chavis's request for appellate review was timely despite the significant delay. This decision was based on California's indeterminate timeline for filing appeals in collateral review cases. The case was brought before the Supreme Court of the United States on a writ of certiorari, where the Court was tasked with determining whether the Ninth Circuit's interpretation of the Antiterrorism and Effective Death Penalty Act (AEDPA) was consistent with its previous rulings, particularly in relation to the tolling of the one-year limitations period for federal habeas corpus petitions. The relevant background context includes the AEDPA's stipulations regarding the time limits for state prisoners to seek federal relief. The Act tolls the one-year period for the time during which a properly filed state post-conviction application is pending. The Supreme Court had previously addressed similar issues in Carey v. Saffold, establishing that the period between an adverse lower court decision and the timely filing of an appeal is not counted against the one-year limit. The Court's decision in this case would clarify how California's unique appeal system fits within the framework established by AEDPA.
Whether the period during which a California prisoner seeks appellate review of an adverse lower court decision is considered "pending" for purposes of tolling the one-year limitations period under the Antiterrorism and Effective Death Penalty Act (AEDPA).
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 9, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
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.
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).
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).