US Supreme Court agrees to hear cases on statute of limitations, personal jurisdiction News
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US Supreme Court agrees to hear cases on statute of limitations, personal jurisdiction

The US Supreme Court Monday granted certiorari to two cases, Reed v. Goertz and Mallory v. Norfolk Southern Railway Company, which focus on statute of limitations and personal jurisdiction issues.

In Reed, petitioner Rodney Reed asked the court to decide when “the statute of limitations begins to run for an action under 42 U.S.C. § 1983 seeking DNA testing of crime-scene evidence on the ground that available state procedures are constitutionally inadequate.” Currently, circuit courts of appeal across the country use different standards to measure such a statute of limitations.

In 1998, a jury convicted petitioner Reed of murdering Stacey Stites. At the time of her death, Stites was in a relationship with Jimmy Fennell, a police officer. Reed contended that he and Stites had a consensual sexual relationship and Fennell murdered her for having an affair with a Black man. Prosecutors argued that Reed kidnapped Stites from the home she shared with Fennell and murdered her. Reed has maintained his innocence for more than two decades and has petitioned repeatedly to have “key crime-scene evidence” DNA-tested.

The Fifth Circuit Court of Appeals ruled that the two-year statute of limitations for Reed’s § 1983 claim started when a state trial court denied Reed’s 2014 request for testing. However, the Texas Court of Criminal Appeals remanded the case for additional findings and released an opinion in 2017, after the statute of limitations had already expired.

In Mallory, the court will decide if a state violates the Due Process Clause of the Fouteenth Amendment if it requires a corporation to consent to personal jurisdiction to conduct business in the state. Petitioner Mallory sued Norfolk in Pennsylvania after he was exposed to carcinogens by the corporation and developed cancer.

To operate in Pennsylvania, foreign corporations must “be incorporated in Pennsylvania, have its principal place of business in Pennsylvania, or have consented to the exercise of jurisdiction.” The Pennsylvania Supreme Court ruled that the such a statutory scheme constitutes “compelled submission to general jurisdiction by legislative command” and violates the Constitution. Mallory appealed to the Supreme Court for review.