Holbrook v. Curtin, No. 14-1247 (6th Cir. 2016)
Annotate this CaseIn 2008, Holbrook was convicted of first-degree murder and sentenced to life imprisonment. The Antiterrorism and Effective Death Penalty Act one-year statute of limitations began to run when his conviction became final in August 2010, 90 days after the Michigan Supreme Court denied leave to appeal. In May 2011, 269 days into that period, Holbrook moved for relief from judgment in state court. The trial court denied the motion. Holbrook sought leave to appeal, which the Michigan Court of Appeals denied on November 8, 2012. Michigan court rules allowed Holbrook until January 3, 2013 to seek leave to appeal. Holbrook filed his application four days after the deadline. The Michigan Supreme Court denied it as untimely on January 11. No later than March 18, 2013, Holbrook filed a federal habeas petition under 28 U.S.C. 2254. The district court dismissed Holbrook’s petition as untimely, “[b]ecause [Holbrook] did not timely seek leave to appeal with the Michigan Supreme Court, the tolling of the limitations period ended when the Michigan Court of Appeals denied leave to appeal on November 8, 2012,” rather than continuing for the 56-day period to appeal. The Sixth Circuit reversed. Holbrook’s federal habeas petition was timely filed because AEDPA’s one-year limitations period was tolled during the period in which he could have, but did not, appeal the Michigan Court of Appeals’ denial of his motion for post-conviction relief.
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