Which Supreme Court decision date controls AEDPA’s newly recognized-right limb?

Section 2244(d)(1)(C) identifies initial Supreme Court recognition of the asserted constitutional right, subject to the newly recognized and retroactively applicable conditions. Do not replace initial recognition with a later retroactivity decision. Compare all applicable accrual limbs and supported tolling.

Responsible actor. A state prisoner asserting a newly recognized constitutional right in a federal habeas claim.

Identify the exact constitutional right asserted and the Supreme Court decision initially recognizing it.

Establish whether the right is newly recognized and made retroactively applicable on collateral review.

Keep the initial-recognition date separate from any later retroactivity ruling.

Compare other applicable accrual limbs, qualifying state-review tolling and separate second-or-successive requirements.

This source guide requires the latest qualifying accrual date, complete review history, claim-specific facts and every supported tolling interval. It supplies no automatic date or paid calculation. A single date cannot establish the limitation period for this procedure.

1. Establish the relevant judgment, asserted claim and governing state-custody or federal-sentence procedure.
2. Compare every applicable statutory accrual limb using the actual review and discovery record.
3. Audit properly filed state collateral applications and their complete qualifying pending intervals.
4. Apply the appropriate time-computation and filing rules only after those legal facts are established.

After establishing the governing accrual event, exclude that event day and examine the corresponding anniversary under the applicable federal time-computation rules. A one-year period must not be replaced mechanically with 365 days across a leap year. This guide does not resolve a February 29 anniversary or supply a running-day ledger. The latest qualifying statutory accrual date and every legally supported excluded interval must be established before arithmetic can represent a filing endpoint. No hypothetical future retroactivity ruling, successful state petition or equitable relief is assumed. Dodd supplies an explicitly labeled comparison, not a misattributed holding on this statute.

Rule 6(a) supplies ordinary weekend, legal-holiday and qualifying clerk-inaccessibility rules where applicable through Habeas Rule 12. Identify the filing district, actual holidays and access facts. A hypothetical Saturday anniversary does not establish the next open filing day in an actual case. A closed-day adjustment cannot itself establish accrual, statutory tolling or equitable relief.

This source guide requires the latest qualifying accrual date, complete review history, claim-specific facts and every supported tolling interval. It supplies no automatic date or paid calculation. A single date cannot establish the limitation period for this procedure.

Assume October 6, 2026 is already established as this claim’s latest qualifying accrual date, with no applicable excluded interval. A corresponding-anniversary illustration reaches October 6, 2027. This arithmetic does not determine whether the assumed legal trigger is correct. October 6, 2027 is an explanatory nominal anniversary only. The guide supplies no automatic filing endpoint.

Assume October 3, 2025 is the established latest accrual date and no excluded interval applies. The corresponding anniversary is Saturday, October 3, 2026. A weekend-only illustration reaches Monday, October 5. Actual district holidays, clerk access and filing facts remain separate checks. Do not publish an automatic Monday filing date without establishing the applicable calendar and all other facts.

Assume the Supreme Court initially recognized a qualifying constitutional right October 6, 2025, and collateral retroactivity was resolved April 1, 2026. Initial recognition and later eligibility confirmation are distinct events. The initial-recognition anniversary illustration is October 6, 2026, not April 1, 2027. Dodd is a section 2255 analogy, not a direct section 2244 holding. Check controlling circuit authority and every statutory condition. Do not reset the date merely because retroactivity was resolved later.

Assume a new-right argument is otherwise timely but the prisoner already filed a federal habeas application challenging the same judgment. The limitation analysis does not determine whether the application is second or successive or whether section 2244(b) authorization and substantive conditions are satisfied. No new filing date or authorization is inferred from the assumed timeliness.

Recognition and eligibility differ

Initial recognition supplies the statutory date. Newness and collateral retroactivity are conditions, not permission to substitute any later decision date.

Dodd is an analogy here

Dodd directly construed section 2255’s similarly worded new-right limb. It is not a direct holding on section 2244(d)(1)(C). Check the controlling circuit’s application.

Successive-petition permission is separate

Section 2244(b) imposes authorization and substantive conditions for a second or successive application. A limitation argument does not establish permission.

Pending state review must qualify

Only actual properly filed qualifying state-review intervals fall within subsection (d)(2).

• This source guide requires the latest qualifying accrual date, complete review history, claim-specific facts and every supported tolling interval. It supplies no automatic date or paid calculation. A single date cannot establish the limitation period for this procedure.
• This guide addresses a constitutional right newly recognized by the Supreme Court. Factual discovery, state-created impediments and direct-review finality are separate accrual limbs.

• Keep the operative judgment, appellate decisions and applicable review-period evidence.
• Document every asserted claim’s statutory accrual basis and supporting diligence record.
• Record each state collateral application’s proper filing and exact pending interval.
• Check the filing district’s rules, holidays, clerk access and inmate-mail evidence.
• Review second-or-successive restrictions separately from limitation arithmetic.
• The state prisoner files the petition with the appropriate federal district court clerk under Section 2254 Rule 3. For an inmate filing, establish timely deposit, use of the institution’s legal-mail system when one exists, and the required declaration or notarized evidence of deposit and prepaid first-class postage. The date counsel receives a judgment or the date a prison later delivers a paper to court is not a substitute for the applicable trigger or proven filing act.