Reed v. Goertz
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Reed v. Goertz and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Reed v. Goertz.
In Reed v. Goertz, the Supreme Court addressed whether Rodney Reed's procedural due process claim regarding Texas's post-conviction DNA testing law was timely filed. The Court determined that the statute of limitations for Reed's § 1983 claim began when the Texas Court of Criminal Appeals denied his motion for rehearing. The Court also considered Reed's standing and Texas's sovereign immunity in the context of his claim.
Holding
The single most important “bottom line” of what the Court decided in Reed v. Goertz.
The Court held that the statute of limitations for Reed's § 1983 procedural due process claim began when the Texas Court of Criminal Appeals denied his motion for rehearing.
Constitutional Concepts
These are the Constitution-related themes that appear in Reed v. Goertz. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Reed v. Goertz
The case centers on whether Texas's post-conviction DNA testing law provided procedural due process.
Syllabus excerpt (verbatim)Reed then sued in federal court under 42 U. S. C. § 1983, asserting that Texas's post-conviction DNA testing law failed to provide procedural due process.
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Why Standing is relevant to Reed v. Goertz
The Court addressed whether Reed had standing to bring his procedural due process claim.
Syllabus excerpt (verbatim)First, Reed has standing because Reed suffciently alleged an injury in fact: denial of access to the requested evidence by the state prosecutor.
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Why State Sovereign Immunity is relevant to Reed v. Goertz
The Court considered whether Texas's sovereign immunity barred Reed's suit.
Syllabus excerpt (verbatim)Second, Texas's invocation of the State's sovereign immunity fails because the Ex parte Young doctrine allows suits like Reed's for declaratory or injunctive relief against state offcers in their offcial capacities.
Key Quotes
Short excerpts from the syllabus in Reed v. Goertz that support the summary and concepts above.
Reed sufficiently alleged an injury in fact: denial of access to the requested evidence.
The statute of limitations begins to run when the plaintiff has a 'complete and present cause of action.'
Reed's procedural due process claim was complete when the state litigation ended.