Third Circuit Revives Habeas on Equitable Tolling Ground

Pennsylvania man is convicted of murder and appeals through the state court system. He ultimately loses at the Pennsylvania Supreme Court but receives no notice of the ruling. Uh oh! When the trial court dockets the Supreme Court's ruling, it gets the date wrong, recording it as March 16, 2015, rather than February 19, 2015. The error is not detected until the man files a federal habeas petition, which is dismissed for being 14 days too late (it would have been timely under the date recorded by the trial court). Is he out of luck? District court: Yup! Third Circuit (unpublished): Nope! Equitable tolling saves the day.

The case is Antonio White v. Superintendent Rockview SCI, No. 20-3511 (3d Cir. 2024)