Reed v. Goertz

Summary

Justice Kavanaugh's majority opinion held that when a prisoner pursues state post-conviction DNA testing through the state-provided litigation process, the limitations period for a § 1983 procedural due process challenge begins when that litigation ends, including disposition of a motion for rehearing. Reed's suit was therefore timely, and the Court reversed the Fifth Circuit. The Court also rejected objections based on standing, sovereign immunity, and the Rooker-Feldman doctrine. Justice Thomas, writing alone, would have vacated and required dismissal for lack of jurisdiction because he viewed the suit as an impermissible challenge to a state-court judgment that lacked traceability and redressability against the prosecutor. Justice Alito, joined by Justice Gorsuch, would have affirmed because Reed's claim accrued no later than the state appellate court's initial decision, rather than its denial of rehearing.