Reed v. Goertz
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Reed v. Goertz and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Reed v. Goertz.
In Reed v. Goertz, the Supreme Court addressed whether Rodney Reed's procedural due process claim regarding Texas's post-conviction DNA testing law was filed within the statute of limitations. The Court determined that the statute of limitations began when the Texas Court of Criminal Appeals denied Reed's motion for rehearing. This decision reversed the Fifth Circuit's ruling that the limitations period started when the trial court initially denied Reed's motion.
Holding
The single most important “bottom line” of what the Court decided in Reed v. Goertz.
The Court held that the statute of limitations for Reed's § 1983 procedural due process claim began when the Texas Court of Criminal Appeals denied his motion for rehearing.
Constitutional Concepts
These are the Constitution-related themes that appear in Reed v. Goertz. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Reed v. Goertz
The case centers on whether Texas's post-conviction DNA testing law provided procedural due process.
Syllabus excerpt (verbatim)Reed then sued in federal court under 42 U. S. C. § 1983, asserting that Texas's post-conviction DNA testing law failed to provide procedural due process.
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Why Standing is relevant to Reed v. Goertz
The Court addressed whether Reed had standing to bring his procedural due process claim.
Syllabus excerpt (verbatim)First, Reed has standing because Reed suffciently alleged an injury in fact: denial of access to the requested evidence by the state prosecutor.
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Why State Sovereign Immunity is relevant to Reed v. Goertz
The Court considered Texas's invocation of state sovereign immunity and found it inapplicable under the Ex parte Young doctrine.
Syllabus excerpt (verbatim)Second, Texas's invocation of the State's sovereign immunity fails because the Ex parte Young doctrine allows suits like Reed's for declaratory or injunctive relief against state offcers in their offcial capacities.
Key Quotes
Short excerpts from the syllabus in Reed v. Goertz that support the summary and concepts above.
Reed sufficiently alleged an injury in fact: denial of access to the requested evidence by the state prosecutor.
The statute of limitations begins to run when the plaintiff has a 'complete and present cause of action.'
The State's alleged failure to provide Reed with a fundamentally fair process was complete when the state litigation ended.
