Third Circuit Reverses District Court’s Order Granting § 2254 Petition for Habeas Corpus

In Satterfield v. Johnson, No. 04-3108 (3d Cir. Jan. 17, 2006), the Third Circuit held that a petition for post-conviction relief that was improperly filed under state law may not be considered "properly filed" for purposes of AEDPA’s tolling statute, § 2244(d)(2). Appeal was taken from the district court’s order granting state inmate’s habeas application under § 2254 based on counsel’s ineffective assistance. The Third Circuit deemed petitioner’s King’s Bench Petition to be improperly filed in the state court proceedings because, inter alia, he filed it with the Pennsylvania Supreme Court instead of the court in which he was convicted, contrary to Pennsylvania’s Post Conviction Relief Act ("PCRA"). Such an improperly filed petition did not toll AEDPA’s one-year statute of limitations, and thus his federal habeas petition was deemed time-barred unless equitable principles warranted tolling of the statute of limitations. In this case, where there were no allegations that the Commonwealth had misled petitioner regarding his claim, the Third Circuit determined that petitioner failed to demonstrate diligence or extraordinary circumstances justifying equitable tolling of AEDPA’s statute of limitations. Thus, the Third Circuit reversed the order granting the habeas petition and remanded for dismissal.