Rodney Reed was found guilty of murder and sentenced to death in Texas. He filed a motion under Texas's post-conviction DNA testing law, requesting DNA testing on certain evidence, which he believed would help identify the true perpetrator. The state trial court denied Reed's motion, citing an inadequate chain of custody for the evidence he sought to test. Reed then sued in federal court, arguing that Texas's post-conviction DNA testing law violated procedural due process. The Fifth Circuit dismissed Reed's claim as time-barred, but the Supreme Court held that the statute of limitations for a procedural due process claim begins to run when the state litigation ends, in this case when the Texas Court of Criminal Appeals denied Reed's motion for rehearing. The Court ultimately reversed the Fifth Circuit's decision and remanded the case for further proceedings.
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