Lawrence v. Florida (2006)
- Docket
- 05-8820
- Decided
- 2006-01-01
Summary
Question: 1) When a defendant facing death has a certiorari petition pending before the United States Supreme Court, does the time the petition is pending count toward the one-year statute of limitations in the Antiterrorism and Effective Death Penalty Act? 2) Does the division in the Circuit Courts over the statute of limitations constitute an extraordinary circumstance that would allow the Court to set aside the time limit? 3) Does the ineffectiveness of a defendant's counsel constitute an extraordinary circumstance that would allow the Court to set aside the time limit? Conclusion: Yes, no, and no. The Court ruled 5-4 that the time a habeas petition is pending before the Supreme Court counts toward the one-year statute of limitations in the Antiterrorism and Effective Death Penalty Act. Section 2244(d)(2) of the Act stops the clock on the time limit while the prisoner appeals in state courts, but the Court ruled that appeals to the Supreme Court are not part of the process referred to in the Act. Justice Clarence Thomas's opinion held that "Read naturally, the text of the statute must mean that the statute of limitations is tolled only while state courts review the application." The Court noted that suspending the statute of limitations for certiorari petitions might cause prisoners to file petitions "as a delay tactic." Finally, the Court rejected Lawrence's equitable tolling claims, holding that attorney miscalculation is not a credible reason for the Court to set aside a deadline.