The following excerpt is from Hinds v. Kernan, Case No.: 17-cv-00379-AJB-JLB (S.D. Cal. 2018):
AEDPA's statute of limitations recognizes three exceptions that may permit review of a petition after the one-year limitation period has expired: (1) statutory tolling under 28 U.S.C. 2244(d)(2); (2) equitable tolling, see Holland v. Florida, 560 U.S. 631, 645 (2010); and (3) in rare and extraordinary circumstances, the fundamental miscarriage of justice exception, which is also referred to in case law as the Schulp gateway or the actual innocence gateway, see McQuiggin v. Perkins, 569 U.S. 383, 386, 392-94 (2013).
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