Plain-English summary
Court rules the clock for a §1983 DNA-testing claim starts when state post‑conviction litigation ends
The Court held that when a prisoner uses state post‑conviction procedures to seek DNA testing, the statute of limitations for a §1983 procedural-due-process claim begins to run only after the state's litigation concludes. The judgment in favor of the state official was reversed and the case sent back for further proceedings.
Why this matters
This decision clarifies when the clock starts for civil-rights lawsuits seeking access to post-conviction DNA testing. It prevents state officials from avoiding federal liability simply because an inmate waited while exhausting the state's procedures, and it gives inmates a clear trigger for when they must file federal §1983 claims after state processes conclude.
Who may feel it
- Prisoners seeking post-conviction DNA testing
- Defense lawyers and innocence advocates
- State prosecutors and correctional officials
- Civil-rights attorneys who bring §1983 claims
Key questions
- Does the statute of limitations for a §1983 procedural-due-process claim seeking state post-conviction DNA testing begin while a prisoner is still litigating in state court, or only after the state litigation ends?