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Holland v. Florida
United States Supreme Court
560 U.S. 631, 130 S.Ct. 2549, 177 L.Ed.2d 130 (2010)
The Anti-Terrorism and Effective Death Penalty act of nineteen ninety six or AEDPA established a one year statute of limitations for a state prisoner to file a federal habeas petition. The clock begins ticking when direct review of the prisoner's sentence is exhausted.
However, the limitations period is paused or told while a state habeas petition is pending.
Another kind of tolling known as equitable tolling pauses a statute of limitations in rare cases to ensure fundamental fairness.
In Holland versus Florida, the Supreme Court considered whether and under what circumstances a prisoner's one year limitations period can be equitably tolled.
A Florida court convicted Albert Holland of first degree murder and sentenced him to death. The Florida Supreme Court affirmed, and the United States Supreme Court denied cert. At this point, Holland had one year to file a federal habeas petition.
Attorney Bradley Collins was appointed to represent Holland in all post conviction proceedings.
Collins filed a state habeas petition that paused the federal limitations period twelve days before it expired.
Over the next three years, as the petition worked its way through the state courts, the men's attorney client relationship deteriorated to the point that Collins stopped responding to Holland's repeated requests for information about his case.
Holland wrote several letters to the Florida Supreme Court requesting that Collins be removed from his case, all to no avail.
Holland also wrote multiple unanswered letters to the court clerk to request updates on his appeal.
Both the trial court and the state supreme court denied relief. The federal limitations period expired twelve days after the supreme court issued its order. However, Holland was unaware of this because Collins never told him about the court's decision.
When Holland found out five weeks later, he immediately filed a pro se habeas petition.
The district court rejected the petition as untimely and held that Holland failed to exercise the due diligence necessary to justify equitable tolling.
The eleventh circuit affirmed, holding that even grossly negligent attorney conduct was insufficient to equitably toll the statute of limitations, even if it didn't involve bad faith, dishonesty, divided loyalty, mental impairment, or similar deficiency.
The United States Supreme Court granted cert.
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Get more case briefs explained with Quimbee. Quimbee has over 42,700 case briefs (and counting) keyed to 988 casebooks ► quimbee.com/case-briefs-overview
Holland v. Florida
United States Supreme Court
560 U.S. 631, 130 S.Ct. 2549, 177 L.Ed.2d 130 (2010)
The Anti-Terrorism and Effective Death Penalty act of nineteen ninety six or AEDPA established a one year statute of limitations for a state prisoner to file a federal habeas petition. The clock begins ticking when direct review of the prisoner's sentence is exhausted.
However, the limitations period is paused or told while a state habeas petition is pending.
Another kind of tolling known as equitable tolling pauses a statute of limitations in rare cases to ensure fundamental fairness.
In Holland versus Florida, the Supreme Court considered whether and under what circumstances a prisoner's one year limitations period can be equitably tolled.
A Florida court convicted Albert Holland of first degree murder and sentenced him to death. The Florida Supreme Court affirmed, and the United States Supreme Court denied cert. At this point, Holland had one year to file a federal habeas petition.
Attorney Bradley Collins was appointed to represent Holland in all post conviction proceedings.
Collins filed a state habeas petition that paused the federal limitations period twelve days before it expired.
Over the next three years, as the petition worked its way through the state courts, the men's attorney client relationship deteriorated to the point that Collins stopped responding to Holland's repeated requests for information about his case.
Holland wrote several letters to the Florida Supreme Court requesting that Collins be removed from his case, all to no avail.
Holland also wrote multiple unanswered letters to the court clerk to request updates on his appeal.
Both the trial court and the state supreme court denied relief. The federal limitations period expired twelve days after the supreme court issued its order. However, Holland was unaware of this because Collins never told him about the court's decision.
When Holland found out five weeks later, he immediately filed a pro se habeas petition.
The district court rejected the petition as untimely and held that Holland failed to exercise the due diligence necessary to justify equitable tolling.
The eleventh circuit affirmed, holding that even grossly negligent attorney conduct was insufficient to equitably toll the statute of limitations, even if it didn't involve bad faith, dishonesty, divided loyalty, mental impairment, or similar deficiency.
The United States Supreme Court granted cert.
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