Manuel Camacho v. Ray Hobbs, 774 F.3d 931

Manuel Enrique Camacho pleaded guilty to capital murder in Arkansas on July 11, 2008; judgment entered July 22, 2008.
Camacho did not file a direct appeal; state postconviction relief was later denied.
He filed a federal habeas petition under 28 U.S.C. § 2254; the State argued the petition was barred by AEDPA’s one-year limitations period.
The magistrate judge and district court concluded the limitations period began on the judgment date (not after the 30‑day appeal window) and dismissed the petition as untimely.
The district court granted a COA on timeliness and equitable tolling; Camacho appealed.
The Eighth Circuit reviewed de novo and held the § 2254 petition was timely, vacating the dismissal and remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does AEDPA’s one‑year clock start for a state conviction entered after a guilty plea when state law generally bars appeals from guilty pleas?	Camacho: clock starts when the state’s time to seek direct review expires (i.e., after the 30‑day appeal period).	State: clock starts on the date the judgment is entered because an unconditional guilty plea bars an appeal.	The clock starts at the expiration of the state filing deadline for seeking direct review (after the 30‑day appeal period); Camacho’s petition was timely.

Clay v. United States, 537 U.S. 522 (uniform federal rule: limitations period runs from conclusion of direct review or expiration of time to seek it)
Jimenez v. Quarterman, 555 U.S. 113 (out‑of‑time direct appeals reset AEDPA finality date)
Gonzalez v. Thaler, 132 S. Ct. 641 (when petitioner forgoes state appeals, finality is the expiration of state‑court filing deadlines)
Artuz v. Bennett, 531 U.S. 4 (distinguishing proper filing questions from merits)
Wright v. Norris, 299 F.3d 926 (8th Cir. standard of review for habeas procedural rulings)