1. This case presents an important question about whether a state court's entry of an amended judgment "nunc pro tunc" prevents that judgment from restarting the federal Antiterrorism and Effective Death Penalty Act of 1996 ("AEDPA")'s statute of limitations period for filing a habeas petition, 28 U.S.C. § 2244(d)(1)(A). In Gonzalez v. Thaler, 565 U.S. 134 (2012), this Court held that § 2244(d)(1)(A)'s limitations period required a "uniform" federal interpretation and rejected "usher[ing] in state-by-state definitions" of its terms. Id. at 152. Courts of appeals have echoed that sentiment, holding that "state law has no bearing on the finality inquiry under AEDPA." Scott v. Hubert, 635 F.3d 659, 664-65 (5th Cir. 2011); accord Crangle v. Kelly, 838 F.3d 673, 680 (6th Cir. 2016) (per curiam) ("[a] state court's decision to affix the label nunc pro tunc to an order does not control" AEDPA's federal statute of limitations period).

Contrary to this Court's instruction that the federal limitations period for habeas petitions should not turn on the idiosyncrasies of state law, the Eleventh Circuit held in this case that "the determining factor" for whether an amended judgment restarts AEDPA's statute of limitations clock is how a state court chooses to label that judgment. Cassidy v. Secretary, Florida Dep't of Corr., 119 F.4th 1336, 1341 (11th Cir. 2024) (quoting Osbourne v. Secretary, Florida Dep't of Corr., 968 F.3d 1261, 1266 (11th Cir. 2020)) (emphasis in Cassidy). As a result, if a petitioner in Alabama, Florida, or Georgia secures an amended judgment that substantively alters her convictions or sentence but the state court labels that judgment nunc pro tunc to the original judgment, the federal limitations period does not reset. Id. But if a state court in Kentucky, Tennessee, Indiana, or Ohio enters an amended judgment using that same label, the limitations period runs anew. Congress did not intend that anomalous result.

Whether a state court's entry of an amended judgment labeled nunc pro tunc prevents that judgment from restarting the federal Antiterrorism and Effective Death Penalty Act of 1996's statute of limitations period for filing a habeas corpus petition under 28 U.S.C. § 2244(d)(1)(A), or whether federal law requires a uniform interpretation independent of state court labeling practices.