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Keywords

attorneystatuteappealstatute of limitationsbad faith

Related Cases

Holland v. Florida, 560 U.S. 631, 130 S.Ct. 2549, 177 L.Ed.2d 130, 78 USLW 4555, 10 Cal. Daily Op. Serv. 7396, 2010 Daily Journal D.A.R. 8838, 22 Fla. L. Weekly Fed. S 437

Facts

Albert Holland was convicted of first-degree murder and sentenced to death in Florida. After the Florida Supreme Court affirmed his conviction, Holland's court-appointed attorney, Bradley Collins, failed to file a timely federal habeas petition despite Holland's repeated requests for updates and timely action. Holland filed a pro se federal habeas petition approximately five weeks late, prompting the District Court to dismiss it as untimely, leading to appeals that questioned the applicability of equitable tolling due to Collins' alleged misconduct.

Issue

Whether the one-year statute of limitations for federal habeas relief under the Antiterrorism and Effective Death Penalty Act (AEDPA) is subject to equitable tolling based on the conduct of Holland's attorney.

Rule

The Supreme Court held that the one-year statute of limitations on petitions for federal habeas relief by state prisoners is subject to equitable tolling in appropriate cases.

Analysis

The Court found that the Eleventh Circuit's rigid standard for equitable tolling, which required proof of bad faith or dishonesty on the part of the attorney, was too restrictive. The Court emphasized that Holland had diligently pursued his rights and that the attorney's failure to communicate and timely file the petition could constitute extraordinary circumstances justifying equitable tolling.

Conclusion

The Supreme Court reversed the Eleventh Circuit's decision and remanded the case for further proceedings to determine whether Holland's circumstances warranted equitable tolling of the AEDPA limitations period.

Who won?

Albert Holland prevailed in the Supreme Court, as the Court recognized the potential for equitable tolling based on his attorney's misconduct.

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Keywords

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