Whether a state court's entry of an amended judgment nunc pro tunc prevents that judgment from restarting the federal statute of limitations period for filing a habeas petition in 28 U.S.C. § 2244(d)(1)(A)

The Antiterrorism and Effective Death Penalty Act of 1996 establishes a oneyear statute of limitations for an individual in state custody to file a federal habeas petition. 28 U.S.C. § 2244(d). As relevant here, that cloc k runs from “the date on which the judgment became final by the conclu sion of direct review or the expiration of the time for seeking such review.” Id. § 2244(d)(1)(A). If an individual secures a new judgment amending her convictions or custodial sentence during direct review, that restarts the limitations period. Had this case arisen in the Sixth Circuit , petitioner would have gotten relief. The rule in that circuit is, regardless of how a state trial court labels a judgment, an amended judgment chan ging an individual’s “conditi ons of confinement” resets the federal limitations period. Crangle v. Kelly , 838 F.3d 673, 680 (6th Cir. 2016) (per curiam). In the Eleventh Circuit, howeve r, a state trial court’s designation of a judgment as “ nunc pro tunc ” to the petitioner’s initial conviction prevents the limitations period from re setting, no matter the substa nce of that judgment. Osbourne v. Secretary, Florida Dep’t of Corr. , 968 F.3d 1261, 1266-67 & n.4 (11th Cir. 2020). The issue in this case is whethe r a state court can prevent the federal limitations period in Section 2244(d)(1)(A) from restarting by labeling an amended judgment nunc pro tunc when that judgment substantively alters a petitioner’s conviction and sentence. The question presented is: Whether a state court’s entry of an amended judgment nunc pro tunc prevents that judgment from restarting the federal statute of limitations period for filing a habeas petition in 28 U.S.C. § 2244(d)(1)(A). ii RELATED CASES Decisions Under Review: Cassidy v. Secretary, Florida Dep’t of Co rr. & Batson v. Florida Dep’t of Corr. , 119 F.4th 1336 (11th Cir. Oct. 28, 2024) (Nos. 21-14257 & 23-13367) (affirming district court in part, vacating in part, and remanding) Batson v. Florida Dep’t of Corr. , 2023 WL 6142460 (S.D. Fla. Sept. 20, 2023) (No. (order di smissing 28 U.S.C. § 2254 petition as untimely) Batson v. Florida Dep’t of Corr. , No. 23-13367 (11th Cir. Jan . 10, 2025) (order denying rehearing) Prior, Related Decisions: Batson v. State , 85 So. 3d 496 (Fla. Dist. Ct. App. Mar. 28, 2012) (No. 4D10-3380) Batson v. State , 211 So. 3d 133 (Fla. Dist. Ct. App. Feb. 1, 2017) (No. 4D15-2728) Batson v. State , 257 So. 3d 134 (Fla. Dist. Ct. App. Nov. 1, 2018) (No. 4D17-2906) Batson v. State , 324 So. 3d 942 (Fla. Dist. Ct. App. Aug. 26, 2021) (No. 4D21-680)