Reed v. Goertz

In Reed v. Goertz, the U.S. Supreme Court addressed a procedural issue concerning Rodney Reed, a Texas death row inmate convicted of the 1996 murder of Stacey Stites. Reed sought DNA testing of crime-scene evidence under Texas law. After the state trial court denied his motion in 2017 and the Texas Court of Criminal Appeals affirmed in 2019, Reed filed a federal civil rights lawsuit under 42 U.S.C. §1983 against District Attorney Bryan Goertz. The lower federal courts dismissed the suit as untimely, ruling the statute of limitations began when the trial court denied testing. The Supreme Court reversed on April 19, 2023, holding that the limitations period does not begin until the state appellate process concludes, because the injury is the denial of testing after all state remedies are exhausted.

The Supreme Court reversed the Fifth Circuit, holding that the limitations period began when the Texas Court of Criminal Appeals denied rehearing in 2019, not when the trial court initially denied testing in 2017. The case was remanded for further proceedings.

Whether the statute of limitations for a 42 U.S.C. §1983 claim seeking DNA testing begins when the state trial court denies the motion or when the state appellate process ends.

The ruling clarifies the timing for federal civil rights claims challenging state denials of post-conviction DNA testing. It reinforces access to DNA evidence for death row inmates and others seeking to prove innocence, potentially affecting wrongful conviction litigation and procedural rules across the United States.