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Supreme Court Decision Update - Day v. McDonough and Northern Insurance Co. of New York v. Chatham County

There were two new Supreme Court decisions issued today:

supreme1.jpgThe first case, Day v. McDonough (PDF of the opinion), concerned how to calculate and apply the one year statute of limitations for filing a federal habeas corpus petition under the Antiterrorism and Effective Death Penalty Act of 1996. The Court held that the District Court in this case was within its discretion to readjust the claimed computation of the statute of limitations and, because the corrected calculation meant the underlying petition was not timely filed, correctly dismissed the case. The majority opinion was written by Justice Ginsburg and joined by Chief Justice Roberts and Justices Kennedy, Souter and Alito.

Justice Stevens filed a dissenting opinion, joined by Justice Breyer. Stevens agreed with the majority’s ultimate disposition of this case (affirming the appellate court’s approval of the original dismissal) but thought that the entry of judgment should have been postponed pending the Supreme Court’s decision in another case, which addresses related issues.

Justice Scalia also filed a dissenting opinion, again joined by Justice Breyer as well as by Justice Thomas. Scalia believes that the majority’s opinion blatantly disregards the Federal Rules of Civil Procedure with regard to habeas corpus cases, which he suggests bars the District Court from readjusting the statute of limitations calculation and dismissing the case when a statute of limitations defense was not originally raised (as it was not in this case).

supreme3.jpgThe second case, Northern Insurance Company of New York v. Chatham County (PDF of the opinion), involved an admiralty suit filed by an insurance company against a Georgia county. The county claimed sovereign immunity to the suit under the Eleventh Amendment, and the District Court dismissed the case, agreeing that sovereign immunity extends to counties and municipalities. The Court’s unanimous opinion, written by Justice Thomas, held that an entity must qualify as an “arm of the State” to be allowed to assert sovereign immunity against an admiralty suit and because the county did not qualify as an “arm of the State,” it was not protected by sovereign immunity.