Supreme Court rules for death-sentence defendant who wants DNA testing

This Supreme Court case involves a brutal 1996 murder. Under normal circumstances, the defendant would lose the case, as the Court is not exactly soft on crime. But this case raises a different issue: what is the statute of limitations when the defendant wants to challenge his conviction on the basis of DNA evidence? The Court rules for the defendant. 

The case is Reed v. Goertz, issued on April 19. The issue is straightforward. After the defendant is convicted of murder and he wants DNA testing to prove he did not commit the crime, how early or late can he file a Section 1983 suit in federal court challenging the DNA process? 

This case arose in Texas. After Reed was sentenced to death, he filed a motion in state court under the Texas DNA testing law. He wanted DNA testing on more than 40 pieces of evidence, including the belt used to strangle the victim. The state trial court rejected Reed's motion, and he also lost his appeal in the Court of Criminal Appeals. Reed next filed a Section 1983 suit, claiming the Texas DNA law violated due process. The federal trial court rejected that argument, and the Fifth Circuit also told Reed to take a hike, holding that the lawsuit was time-barred because the statute of limitations began to run when the Texas trial court denied Reed's motion, more than two years before Reed filed his Section 1983 case. Reed took his case to the Supreme Court, arguing that the statute of limitations began to run when the state-court litigation ended, which includes the appellate process, not simply when the trial court ruled against him.

The Supreme Court revives the Section 1983 suit. As a general rule, the SOL starts to run "when the plaintiff has a complete and present cause of action." The Court said that in 1997. That principle helps Reed, the Court says, because "the State's alleged failure to provide Reed with a fundamentally fair process was complete when the state litigation ended and deprived Reed of his asserted liberty interest in DNA testing. Therefore, Reed's Section 1983 claim was complete and the statute of limitations ended when the Texas Court of Criminal Appeals denied Reed's motion for rehearing."

The Court notes that its holding in this case makes sense because a contrary ruling would have plaintiff proceed to federal court under Section 1983 and handle his state court appeal at the same time. Twin proceedings in two different court are a bad thing. Also, allowing the state appellate process to proceed might cure any problems with the DNA process and make the Section 1983 suit unnecessary.

Justice Kavanaugh wrote the majority opinion, joined by Roberts, Jackson, Kagan and Sotomayor. Thomas dissents, arguing that federal courts simply lack jurisdiction to review any state court judgments. Alito and Gorsuch file a separate dissent.