Reed v. Goertz

Reed v. Goertz, 598 U.S. ___ (2023), is a United States Supreme Court case regarding the statute of limitations.

Background
A Texas jury found Rodney Reed guilty of the murder of Stacey Stites. He was sentenced to death. In 2014, Reed filed a motion in Texas state court under the state's post-conviction DNA testing law. He requested DNA testing on certain pieces of evidence, including the belt used to strangle Stites. The state court denied Reed's motion, reasoning that the items Reed requested to be tested were not preserved through an adequate chain of custody. The Texas Court of Criminal Appeals agreed and denied Reed's motion for a rehearing. Reed then sued in federal court under 42 U.S. Code §1983, a U.S. Code allowing citizens to sue state officials for violating civil rights, claiming that Texas's post-conviction DNA testing law failed to provide procedural due process. Reed also argued that the law's strict chain of custody requirements was unconstitutional. The District Court dismissed his complaint while The Fifth Circuit affirmed on the ground that Reed’s §1983 claim was filed too late, after the applicable 2-year statute of limitations had run. The Fifth Circuit held that the limitations period began to run when the Texas trial court denied Reed’s motion, not when the Texas Court of Criminal Appeals denied rehearing.

Supreme Court decision
Reed sought review of the Fifth Circuit decision by the Supreme Court and filed a writ of certiorari. The Supreme Court decided 6-3 that the limitations began when state litigation ended, which was when the Texas Court of Criminal Appeals denied Reed's motion for rehearing on the DNA testing claim, reversing the Fifth Circuit's decision. It is unclear when Reed's execution will occur.