Robbins: Conviction becomes final after sentence becomes final

In Robbins v. Sec. Dep’t of Corrections, No. 05-14992 (Apr. 3, 2007), the Court reversed the dismissal on untimeliness grounds of a § 2254 habeas petition. Accepting the State’s confession of error, the Court ruled that a conviction is not final until affirmed on direct appeal. Here, the state court imposed a sentence on resentencing, and Robbins’ statute of limitations began to run after this sentence became final, subsequent to his conviction.