09-5327 Holland v. Florida

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Habeas Corpus
Equitable tolling

28 U.S.C. 2244(d), the AEDPA statute of limitations, is subject to equitable tolling in appropriate cases.
Several considerations support the Court’s holding. First, because AEDPA’s “statute of limitations defense . . . is not ‘jurisdictional,’ ” Day v. McDonough, 547 U. S. 198, 205, 213, it is subject to a “rebuttable presumption” in favor “of equitable tolling,” Irwin v. Department of Veterans Affairs, 498 U. S. 89, 95–96. That presumption’s strength is reinforced here by the fact that “equitable principles” have traditionally “governed” substantive habeas law. Munaf v. Geren, 553 U. S. 674, ___, and the fact that Congress enacted AEDPA after Irwin and therefore was likely aware that courts, when interpreting AEDPA’s timing provisions, would apply the presumption, see, e.g., Merck & Co. v. Reynolds, 559 U. S. ___, ___. Second, §2244(d) differs significantly from the statutes at issue in United States v. Brockamp, 519 U. S. 347, 350–352, and United States v. Beggerly, 524 U. S. 38, 49, in which the Court held that Irwin’s presumption had been overcome. For example, unlike the subject matters at issue in those cases—tax collection and land claims— AEDPA’s subject matter, habeas corpus, pertains to an area of the law where equity finds a comfortable home. See Munaf, supra, at ___. Brockamp, supra, at 352, distinguished. Moreover, AEDPA’s limitations period is neither unusually generous nor unusually complex. Finally, the Court disagrees with respondent’s argument that equitable tolling undermines AEDPA’s basic purpose of eliminating delays in the federal habeas review process, see, e.g., Day, supra, at 205–206. AEDPA seeks to do so without undermining basic habeas corpus principles and by harmonizing the statute with prior law, under which a petition’s timeliness was always determined under equitable principles. See, e.g., Slack v. McDaniel, 529 U. S. 473, 483. Such harmonization, along with the Great Writ’s importance as the only writ explicitly protected by the Constitution, counsels hesitancy before interpreting AEDPA’s silence on equitable tolling as congressional intent to close courthouse doors that a strong equitable claim would keep open.
539 F. 3d 1334, reversed and remanded. Local effect: The opinion is consistent with governing Seventh Circuit precedent. Taliani v. Chrans, 189 F.3d 597, 598 (7th cir. 1999).

09-5327 Holland v. Florida

Breyer, J.; Alito, J., concurring in part; Scalia, J., dissenting.