Section 2254

The Court held that the district court erred in dismissing the petitioner’s § 2254 motion as untimely after he filed a defective postconviction motion in state court. The Court held that the petitioner’s amended motion related back to the original filing, thus tolling the AEDPA’s statute of limitations from the time of the original filing until the amended motion was denied with prejudice.

The Court held that it lacked subject matter jurisdiction to review the district court’s denial of a § 2254 petitioner’s motions for substitute counsel. The orders were not final orders under 28 U.S.C. § 1291 and did not fall under the collateral order doctrine since orders could be reviewed in an appeal from a denial of the petitioner’s §2254 motion.

The Court reversed the district court’s denial of petitioner’s § 2254 motion, finding that petitioner received ineffective assistance of counsel when trial counsel failed to object or move for a mistrial after the court coerced a deadlocked jury into reaching a verdict. In response to reports that a lone juror was holding out, the trial court issued a formal Allencharge, three additional instructions to continue deliberating, and removed all of the reading material from the jury room after hearing that the holdout juror was doing crossword puzzles.

The Court affirmed the district court’s order dismissing the petitioner’s § 2254 motion as time-barred, since the statute of limitations began running when the petitioner missed the deadline for appealing his conviction to the highest court in the state of conviction, and not after that court’s order dismissing the petitioner’s untimely appeal filed after that deadline.