Pace v. DiGuglielmo, 544 U.S. 408 (2005)

In February 1986, John A. Pace pleaded guilty to second-degree murder and possession of an instrument of crime in a Pennsylvania state court, resulting in a life sentence without the possibility of parole. Following his conviction, Pace did not file a motion to withdraw his guilty plea or a direct appeal. Instead, he filed a petition under the Pennsylvania Post Conviction Hearing Act (PCHA) in August 1986, which concluded in September 1992 when the Pennsylvania Supreme Court denied his untimely request for discretionary review. Over four years later, on November 27, 1996, Pace filed another postconviction petition under the newly enacted Pennsylvania Post Conviction Relief Act (PCRA), which included a statute of limitations for such petitions. The procedural history of the case began with the dismissal of Pace's PCRA petition by the Court of Common Pleas on July 23, 1997, which noted that his claims had already been litigated and were meritless. After Pace appealed, the Commonwealth argued that his PCRA petition was untimely, leading the Superior Court to dismiss it on December 3, 1998, for failing to meet the statutory time limits. The Pennsylvania Supreme Court subsequently denied review of the case on July 29, 1999. Following these state court proceedings, Pace filed a federal habeas corpus petition in December 1999, which was initially recommended for dismissal based on AEDPA's statute of limitations. However, the District Court rejected this recommendation, leading to further appeals. The relevant background context includes the enactment of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), which established a one-year statute of limitations for federal habeas corpus petitions. This statute allows for tolling of the limitations period while a properly filed state post-conviction application is pending. The central issue in this case was whether Pace's PCRA petition, which was deemed untimely by the state courts, could be considered "properly filed" under AEDPA's provisions, ultimately leading the Supreme Court to determine that it was not, thus rendering Pace's federal petition time-barred.

Whether a state postconviction petition rejected by the state court as untimely is considered "properly filed" within the meaning of the federal Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) for the purposes of tolling the 1-year statute of limitations for filing a federal habeas corpus petition.

The judgment is reversed.