Reed v. Goertz
The Facts
Rodney Reed was convicted of the rape and murder of Stacey Stites in Bastrop County, Texas, and sentenced to death. For years he sought forensic testing of biological evidence recovered from the crime scene, arguing it would exonerate him. Texas courts repeatedly denied his requests for testing under the state's DNA testing statute. Reed brought a Section 1983 action challenging the denial as a violation of due process. The question was whether his claim was time-barred.
The Application
Reed's injury, the state's denial of due process in refusing DNA testing, could not trigger accrual until the state courts' decision-making process was complete. Because Reed pursued multiple requests and appeals through Texas's court system, the statute of limitations began not at the first trial court denial but at the end of all state appellate review. This timing preserved Reed's Section 1983 claim despite the years elapsed during his exhaustion of state remedies, ensuring that procedural mechanics did not foreclose his federal civil rights action before he could vindicate it in federal court.
The Conclusion
**The Supreme Court held 6-3 that Reed's limitations period began at the end of state-court litigation, not at the initial denial of his DNA testing request.** His Section 1983 claim was therefore timely and could proceed, keeping alive the possibility of testing evidence in his capital case.
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Case Analysis
Overview
Texas death-row prisoner Rodney Reed sought post-conviction DNA testing of evidence from his 1998 murder conviction and brought a civil rights suit when Texas refused. The Supreme Court held 6-3 that the limitations period for his due process challenge began running at the end of state-court litigation, not at the moment of the first denial, allowing his claim to proceed.
Facts
Rodney Reed was convicted of the rape and murder of Stacey Stites in Bastrop County, Texas, and sentenced to death. For years he sought forensic testing of biological evidence recovered from the crime scene, arguing it would exonerate him. Texas courts repeatedly denied his requests for testing under the state's DNA testing statute. Reed brought a Section 1983 action challenging the denial as a violation of due process. The question was whether his claim was time-barred.
Issue
When does the statute of limitations begin to run on a Section 1983 claim that the state's post-conviction DNA testing statute, as applied, violates due process. At the initial denial of a DNA testing request, or at the conclusion of all state-court litigation over that denial?
Rule
A Section 1983 claim accrues when the plaintiff knows or has reason to know of the injury that is the basis of the action. For claims challenging the outcome of state-court proceedings under procedural due process, the injury is final when the state court litigation has concluded. The limitations period therefore begins running at the end of state appellate review, not at the first administrative or trial court denial.
Analysis
Reed's injury, the state's denial of due process in refusing DNA testing, could not trigger accrual until the state courts' decision-making process was complete. Because Reed pursued multiple requests and appeals through Texas's court system, the statute of limitations began not at the first trial court denial but at the end of all state appellate review. This timing preserved Reed's Section 1983 claim despite the years elapsed during his exhaustion of state remedies, ensuring that procedural mechanics did not foreclose his federal civil rights action before he could vindicate it in federal court.
Conclusion
**The Supreme Court held 6-3 that Reed's limitations period began at the end of state-court litigation, not at the initial denial of his DNA testing request.** His Section 1983 claim was therefore timely and could proceed, keeping alive the possibility of testing evidence in his capital case.
Notes
OT2022. Added via SCOTUS bulk import 2026-05-14
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