Facts of the Case

Provided by Oyez

Rodney Reed was sentenced to death in Texas for the 1996 rape and murder of Stacey Stites. He unsuccessfully sought federal post-conviction relief, and when the state asked to set an execution date, Reed requested to have DNA testing conducted on several items on or near the victim’s body. A state trial court declined his request. Reed then filed a federal civil rights lawsuit under 42 U.S.C. § 1983 challenging the constitutionality of the Texas law governing post-conviction DNA testing. The district court dismissed his claim, and the U.S. Court of Appeals for the Fifth Circuit affirmed the dismissal on the grounds that Reed’s claims are barred by the state’s two-year statute of limitations for personal injury claims, which begins to run as soon as the plaintiff becomes aware that he has suffered an injury.”

Questions

  1. When does the statute of limitations for a 42 U.S.C. § 1983 claim seeking DNA testing of crime-scene evidence begin to run?

Conclusions

  1. When a prisoner pursues state post-conviction DNA testing through the state-provided litigation process, the statute of limitations a procedural due process claim under 42 U.S.C. § 1983 begins to run when the state litigation ends. Justice Brett Kavanaugh authored the 6-3 majority opinion holding that, in Reed’s case, the statute of limitations on his § 1983 claim began when the Texas Court of Criminal Appeals denied his motion for rehearing, not when the state trial court denied DNA testing.

    A statute of limitations begins to run when a plaintiff has “a complete and present cause of action.” When that occurs depends on the cause of action. The violation of procedural due process rights, as Reed alleged in this case, requires two elements: (1) deprivation by state action of a protected interest in life, liberty, or property, and (2) inadequate state process. Thus, a plaintiff has “a complete and present cause of action” for a procedural due process violation not at the time of deprivation, but at the time the state fails to provide due process. In Reed’s case, the State’s alleged failure to provide him with a fundamentally fair process was complete when the state litigation ended and deprived Reed of his asserted liberty interest in DNA testing.

    Justice Clarence Thomas dissented, arguing that the district court lacked jurisdiction to hear the case for lack of standing. Justice Thomas would dismiss the case on the finding that Reed’s action presents no original Article III case or controversy between him and the district attorney.

    Justice Samuel Alito authored a dissenting opinion, in which Justice Neil Gorsuch joined, arguing that there are a number of points in the case at which the statute of limitations could begin to run—all before the denial by the Criminal Court of Appeals, and all leading to the conclusion that Reed’s claim is time-barred.