Clarence Borns v. Troy Chrisman, Warden

AEDPA imposes a one-year statute of limitations on federal habeas petitions filed by state prisoners. 28 U.S.C. § 2244(d)(1). That period is tolled, however, while a “properly filed application for State post-conviction or other collateral review” is pending. § 2244(d)(2). For pro se prisoners, whose ability to deposit court papers depends on the prison mail system, the date a state postconviction motion is “filed” is often dispositive of whether the federal habeas petition will be heard at all. In Houston v. Lack, 487 U.S. 266 (1988), this Court held that a pro se prisoner’s federal court papers are deemed filed when delivered to prison authorities for mailing. But that straightforward rule has split the circuits over a variation on the theme. Different circuits come to different conclusions about whether Houston governs when a state postconviction motion is “filed” under § 2244(d)(2), or whether— as the Sixth Circuit held below—only state filing rules govern, leaving federal habeas timeliness to depend entirely on the procedural choices each State has made. The question presented is: Does state or federal law govern the date a pro se prisoner’s state postconviction motion is “filed” for purposes of tolling AEDPA’s one-year limitations period under 28 U.S.C. § 2244(d)(2)?