Supreme Court of the United States
Evans, Acting Warden v. Chavis
January 10, 2006546 U.S. 189
Summary
The Court reversed the Ninth Circuit, holding that a federal court cannot presume a state habeas petition tolls the AEDPA limitations period merely because the state court denied it on the merits or without comment. Instead, the court must examine whether the delay between state court decisions was reasonable under California law. Justice Stevens concurred in the judgment but disagreed with the reasoning, advocating for presumptions based on delay length.