Summary
The Supreme Court denied certiorari in a federal habeas corpus appeal concerning whether a newly commissioned expert report could restart the one-year statute of limitations for filing a habeas petition under 28 U.S.C. § 2244(d)(1)(D). Justice Alito, joined by Justice Thomas, issued a statement explaining that the Sixth Circuit incorrectly treated corroborating evidence for a previously available claim as sufficient to revive a time-barred petition. The Court declined to summarily reverse because the petitioner had already completed her sentence, but cautioned lower courts not to view the denial as endorsement of the Sixth Circuit's ruling.
Topics
Practice areas
Questions Presented
- Whether the Sixth Circuit erred in reviving a time‑barred habeas petition under 28 U.S.C. §2244(d)(1)(D) based on newly discovered expert evidence.
Key quotations
“The Court’s unwillingness to summarily reverse is understandable, and it is possible to view the decision below as an aberrant decision attributable to the particular facts of this case and not as a precedent that will be followed in future cases.” (at 3)
Factual background
Kayla Ayers was convicted in 2013 of aggravated arson and child endangerment. At trial the State presented testimony and an expert fire‑inspection report indicating two ignition points. Ayers's trial counsel did not retain an independent fire expert. In 2019 Ayers's post‑conviction counsel obtained a new fire‑inspection report and used it to argue ineffective assistance of counsel.
Procedural history
The Sixth Circuit reversed the district court's dismissal of Ayers's federal habeas petition on timeliness grounds; the Supreme Court denied certiorari.