Albert Holland v. Florida

Summary

The Court held that AEDPA's one-year limitations period for federal habeas petitions, 28 U.S.C. § 2244(d), is subject to equitable tolling in appropriate cases, and that the Eleventh Circuit's per se rule—under which attorney negligence, even gross negligence, could never constitute an 'extraordinary circumstance' absent bad faith, dishonesty, divided loyalty, or mental impairment—was too rigid. It further held that the petitioner pursued his rights with the 'reasonable diligence' equity requires, and it reversed and remanded for the lower courts to determine in the first instance whether counsel's years-long failures to communicate, to research the deadline, and to file or inform constituted extraordinary circumstances warranting tolling. Justice Alito concurred in part and in the judgment, emphasizing that tolling turns on whether counsel's misconduct is fairly attributable to the client, such as effective abandonment; Justice Scalia, joined by Justice Thomas as to all but Part I, dissented, arguing that § 2244(d) leaves no room for equitable tolling and that attorney error is attributable to the client.