Lawrence v. Florida, 549 U.S. 327 (2007)
Primary Holding
A 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.
In the case of Lawrence v. Florida, the Supreme Court decided that once a state court has made a final decision on a legal issue, that issue is no longer considered "pending," even if a request to the Supreme Court for review is still in progress. This ruling matters because it sets a clear limit on how long someone can wait to file a federal appeal after exhausting state options, which can affect individuals seeking justice after a conviction. For consumers, this case is relevant if they are involved in a legal situation where they are considering appealing a state court decision, as it highlights the importance of acting quickly within the set time limits.
AI-generated plain-language summary to help you understand this case
In Lawrence v. Florida, 549 U.S. 327 (2007), the underlying events began with Gary Lawrence and his wife committing the murder of Michael Finken using a pipe and a baseball bat. Following their actions, a Florida jury convicted Lawrence of first-degree murder, conspiracy to commit murder, auto theft, and petty theft, leading to a death sentence. The Florida Supreme Court affirmed his conviction and sentence, and the U.S. Supreme Court denied certiorari on January 20, 1998. After the state court's final judgment, Lawrence filed an application for state postconviction relief on January 19, 1999, which was 364 days after his conviction became final. The state trial court denied his application, and the Florida Supreme Court affirmed this decision, issuing its mandate on November 18, 2002. Lawrence then sought review in the U.S. Supreme Court, which denied certiorari on March 24, 2003. Subsequently, Lawrence filed a federal habeas corpus application, but the Federal District Court dismissed it as untimely, as he had exceeded the one-year statute of limitations set by the Antiterrorism and Effective Death Penalty Act (AEDPA). The procedural history indicates that the Eleventh Circuit upheld the District Court's dismissal, concluding that Lawrence had only one day remaining to file his federal habeas application after the Florida Supreme Court issued its mandate. The court's decision was influenced by existing precedent, which stated that the statute of limitations under §2244 was not tolled during the pendency of a petition for certiorari in the U.S. Supreme Court. The Supreme Court granted certiorari to address this issue and ultimately affirmed the Eleventh Circuit's ruling.
Whether a state application for post-conviction relief is still considered "pending" under 28 U.S.C. §2244(d)(2) when a petition for certiorari has been filed in the Supreme Court after the state courts have entered a final judgment on the matter.
The judgment is affirmed.
- Court
- Supreme Court
- Decision Date
- October 31, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Thomas
- Damages Awarded
- N/A
- Data Quality
- high
Allen v. Siebert, 552 U.S. 3 (2007)
Consumer LostA 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.
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.
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.
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.