Supreme Court of the United States
Evans, Acting Warden v. Chavis
January 10, 2006546 U.S. 189
Summary
The Court held that federal courts must examine the length of delay in a California state habeas petition to determine if it was filed within a 'reasonable time' for AEDPA tolling purposes, rather than presuming timeliness based on a silent Supreme Court denial. The Court concluded a 3-year delay was unreasonable. Justice Stevens concurred in the judgment, disagreeing with the majority's requirement for federal courts to determine reasonableness de novo and instead proposing presumptions based on state court orders.