United States First Circuit

District court's dismissal of defendant's request for habeas relief as untimely is vacated and remanded where: 1) the district court was correct in concluding that mental illness can constitute an extraordinary circumstance which may prevent a habeas petitioner from understanding and acting upon his legal rights and thereby equitably toll the AEDPA limitations period; 2) mental illness does not per se toll the AEDPA limitations period, as there must be some causal link between a petitioner's mental illness and his ability seasonably to file for habeas relief; and 3) the district court's determination that defendant was not entitled to equitable tolling rests on too unsteady a foundation.

Appellate Information

• Decided 08/05/2010
• Published 08/05/2010

Judges

• SELYA

Court

• United States First Circuit

Counsel

• For Appellant:
  
• Randy Gioia, Annette C. Benedetto