Brown: Letters to parole board don't toll AEDPA

In Brown v. Barrow, No. 06-11004 (Jan. 11, 2008), the Court held that a Georgia inmate’s federal habeas petition challenging a denial of parole was time-barred by AEDPA’s one-year statute of limitations, when it was filed seven years later. The Court rejected the argument that the inmate’s letters to the parole board tolled the limitations period. The Court noted that Georgia has long provided that the sole means to attack a denial of parole was to file a writ of mandamus in state court, and Brown did not do this sufficiently early to avoid the one-year time-bar.