Heleva v. Brooks’s Empirical Analysis

Citation profile

3 federal appellate · 3 district · 1 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “A prisoner seeking postconviction relief might avoid this predicament ... by filing a “protective” petition in federal court and asking the federal court to stay and abey the federal habeas proceedings until state remedies are exhausted .... A petitioner’s reasonable confusion about whether a state filing would be timely will ordinarily constitute “good cause” for him to file in federal court.”

   1 later decision quote this exact passage · from the majority
   e.g. Mena v. Long

2. “To be clear, though we hold that good cause as described in Rhines and Pace does at least encompass more than mixed petitions, we reserve judgment on whether the scenario laid out by Heleva — a habeas petitioner with only hours remaining in the AEDPA limitations period — may qualify as good cause.”

   1 later decision quote this exact passage · from the dissent
   e.g. 768 F. Supp. 2d 1277 - Wright v. Oubre

3. “reasonable confusion about whether a state filing would be timely will ordinarily constitute 'good cause' for [a petitioner] to file in federal court”

   1 later decision quote this exact passage · from the dissent
   e.g. Sena v. Kenneway