Pace v. DiGuglielmo

In 1986, John Pace (defendant) pleaded guilty to second-degree murder and related offenses in Pennsylvania state court and was sentenced to life in prison without parole. Pace did not directly appeal his conviction, but he filed a state postconviction petition that Pennsylvania courts denied in 1992. Pennsylvania then passed a law that imposed a statute of limitations on state postconviction petitions. In 1996, Pace filed a second postconviction petition, but it did not mention timeliness or plead any exception to the statute of limitations. The Pennsylvania Superior Court determined that Pace’s petition was untimely, and the Pennsylvania Supreme Court denied review on July 29, 1999. On December 24, 1999, Pace filed a federal habeas petition. The federal district court found that it could consider Pace’s habeas petition because Pace’s second postconviction petition was properly filed even though it was untimely, and therefore that postconviction petition paused the one-year clock to file Pace’s habeas petition until July 29, 1999. The United States Court of Appeals for the Third Circuit reversed the district court, finding that Pace’s second postconviction petition was improperly filed because it was untimely and thus Pace’s habeas petition was time-barred. The Supreme Court granted certiorari. Pace argued in part that there is a distinction between proper-filing conditions that are necessary for a court clerk to accept a petition and procedural rules that require judicial analysis.