RonRico Simmons, Jr. v. United States
HabeasCorpus Punishment
Whether a court can summarily dismiss a pro se habeas petition as untimely for failure to adequately allege a causal connection
QUESTION PRESENTED To promote the finality of criminal judgments, the Antiterrorism and Effective Death Penalty Act (AEDPA) generally imposes a one-year limitations period on habeas petitions. Recognizing the fundamental importance of the habeas writ to our constitutional freedoms, however, AEDPA also provides several exceptions to that limit, including when a government impediment “in violation of the Constitution or laws of the United States” “prevent[s]” prisoners from timely filing their petitions. 28 U.S.C. § 2255(f)(2). AEDPA also provides that, when a court cannot decide a habeas motion on the pleadings, it must conduct an evidentiary hearing “[u]nless the motion and the files and records of the case conclusively show that the prisoner is entitled to no relief.” 28 U.S.C. § 2255(b). The question presented is: whether a court can summarily dismiss a pro se habeas petition as untimely for failure to adequately allege a causal connection when petitioner explains how a government impediment “prevented” him from filing timely, but does not allege with specificity how he discovered and attempted to remedy that impediment. (i)