The following excerpt is from Burrows v. California, Case No. 1:15-cv-01569 LJO MJS (HC) (E.D. Cal. 2016):
The limitations period commenced on April 25, 1996, the day after AEDPA became law and expired one year thereafter on April 24, 1997. Petitioner did not file any state post-conviction applications until 2014. Petitions filed after the expiration of the statute of limitations period have no tolling effect. Ferguson v. Palmateer, 321 F.3d 820 (9th Cir. 2003) ("section 2244(d) does not permit the reinitiation of the limitations period that has ended before the state petition was filed.").
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.