New York Court of Appeals
In the Matter of Jason Grant v. Daniel Senkowski, as Superintendent of Clinton Correctional Facility
February 13, 200195 N.Y.2d 605
Summary
The New York Court of Appeals affirmed the dismissal of an inmate's Article 78 proceeding as time‑barred, holding that under CPLR 304 filing requires delivery to the court clerk, not to prison officials, and that the pro se prisoner "mailbox rule" from Houston v. Lack does not apply.