Wood v. Milyard
|Docket No.||Op. Below||Argument||Opinion||Vote||Author||Term|
Feb 27, 2012
|Apr 24, 2012||9-0||Ginsburg||OT 2011|
Holding: Courts of appeals, like district courts, have the authority – but not the obligation – to raise a forfeited timeliness defense on their own initiative in exceptional cases. Because the state in this case had deliberately waived the statute of limitations defense, the court of appeals abused its discretion when it dismissed Wood’s habeas petition as untimely.
Plain English Summary: A state prisoner who is challenging his conviction in federal court on the ground that it was unconstitutional must file his challenge within one year after his state court conviction becomes final. If the prisoner files his challenge late, then the state may win a dismissal of the lawsuit simply on the grounds that the lawsuit is untimely. In this case, the Supreme Court considered whether an appellate court could dismiss the prisoner’s case because he filed his challenge too late even when the state did not argue that the lawsuit was too late. The Court held that, in exceptional cases, the lower court can dismiss the case, but it is not required to do so. Here, when the state specifically recognized that the challenge was filed late but declined to argue that the lateness warranted dismissal, the lower court should not have dismissed the lawsuit.
Judgment: Reversed, 9-0, in an opinion by Justice Ginsburg on April 24, 2012. Justice Thomas filed an opinion concurring in the judgment, which Justice Scalia joined.
- Opinion analysis: An appellate court lacks discretion to override a state’s deliberate waiver of AEDPA’s limitations defense (Scott Dodson)
- Argument recap: Disregarding a state’s litigation decisions on habeas (Scott Dodson)
- Argument preview: Appellate authority to raise AEDPA limitations sua sponte (Scott Dodson)