Habeas cases are increasingly rule-based, and federal courts won't relax these hyper-technical rules even when it's shown a prosecutor withheld Brady material and an eyewitness recanted his testimony. Daniels v. Uchtman (CA7 8.29.05).
A prisoner can't seek federal habeas relief until after he has exhausted state court remedies. The plaintiff has one-year from the time of being denied state court relief to file a federal habeas petition. Another rule provides that a prisoner has only one year to seek federal habeas relief after he has learned of new evidence that casts his conviction into doubt. What happens when these rules collide? Answer: a person who was denied a fair trial is screwed.
In Daniels v. Uchtman, a juvenile deliquent was the primary witness against the defendant. The juvenile deliquent was facing a pending burglarly charge, but promised a break if he would testify against Mr. Daniels. The prosecutor never told the defense about the pending burglarly case. The jury convicted.
Fifteen years later, the witness recanted his testimony. Within one-year, Mr. Daniels' defense team sought state court relief. Within one-year of being denied state court relief, the defense team sought federal court relief. The district court dismissed the petition as untimely, and the appellate court affirmed, writing that
the statute ran for a total of 123 days from the signing of the affidavit until Daniels filed for relief in state court. At that point, the statute was tolled. After the Illinois Supreme Court denied relief, the statute began to run again, this time for 364 days until Daniels filed his habeas petition. In the view of the district court, a total of 487 days elapsed after the date on which the factual predicate of Daniels’ claims had been discovered, making his habeas petition untimely.
Daniels is problematic since courts sometimes toll the statute of limitations. Where, as here, the prisoner makes a good faith effort to comply with the (exceedingly complex) rules governing the writ of habeas corpus, federal courts should hear their claims. After all, the write of habeas corpus is a constitutional right: hyper-technical rules standing in the way of this right are themselves violative of due process.
But that's neither here nor there. We're left with Daniels, and we must understand it. Sadly, the message from Daniels seems clear. File fast - since it's practically impossible to know the deadlines in advance.