What is the current state of the law on tolling claims for post-conviction relief?

In Gibbs v. Legrand, 767 F.3d 879 (9th Cir.2014), we adopted the stop clock approach to analyzing claims for equitable tolling. Under that approach, the statute-of-limitations clock stops running when extraordinary circumstances first arise, but the clock resumes running once the extraordinary circumstances have ended or when the petitioner ceases to exercise reasonable diligence, whichever occurs earlier. Id. at 89192. In that sense, the stop-clock approach to equitable tolling works in much the same way statutory tolling does under 28 U.S.C. 2244(d)(2) : Any period during which both extraordinary circumstances and diligence are shown does not count toward the statute of limitations, just as any period during which a properly filed application for state post-conviction relief is pending does not count toward the statute of limitations. See Wood v. Milyard, U.S. , 132 S.Ct. 1826, 1831 & n. 3, 182 L.Ed.2d 733 (2012). To determine whether a petition is timely, we ask whether it was filed within the 1year limitations period after all periods of tolling are subtracted from the count.