Reed v. Goertz

Rodney Reed, a Texas death row inmate convicted of the 1996 murder of Stacey Stites, sought DNA testing on crime-scene evidence under Texas law. After state courts denied his motion, Reed filed a federal civil rights lawsuit under 42 U.S.C. §1983 against prosecutor Bryan Goertz, challenging the constitutionality of Texas's DNA testing statute. The district court dismissed the suit as time-barred. The Supreme Court granted certiorari to resolve a circuit split on when the statute of limitations begins to run. On April 19, 2023, the Court ruled 6-3 that Reed's claim was timely because it accrued when the state-court litigation ended, not when the DNA testing was initially denied. The decision allowed Reed to pursue his federal challenge.

The U.S. Supreme Court reversed the Fifth Circuit, holding 6-3 that Reed's §1983 claim was timely. Writing for the majority, Justice Thomas found that the claim accrued when the Texas Court of Criminal Appeals denied Reed's motion for rehearing, making the state-court litigation final. The case was remanded for further proceedings on the merits of Reed's constitutional challenge.

The central dispute was whether Reed's §1983 claim was barred by the statute of limitations. The Court had to determine when the claim accrued: at the moment the state trial court denied DNA testing, or when the appeals process concluded. A related question was whether a §1983 suit was the proper procedural vehicle to challenge a state's post-conviction DNA testing procedures.

The ruling clarified the statute of limitations for §1983 claims in the post-conviction DNA testing context, resolving a circuit split. It reinforced death penalty inmates' ability to seek federal review of state DNA testing denials. The case drew national attention to Reed's long-standing innocence claims, with supporters including celebrities and innocence projects highlighting potential flaws in the original conviction. The decision was seen as a procedural victory for access to forensic evidence.