The following excerpt is from Roberson v. Martel, No. 2:18-cv-0586 AC P (E.D. Cal. 2019):
Aside from the fact that petitioner does not indicate that his mental health issues were severe enough to constitute "extraordinary circumstances" warranting equitable tolling of the statute of limitations (see Holland v. Florida, 560 U.S. 631, 649 (2010) ("extraordinary circumstances" requirement)), petitioner also fails to provide any specifics regarding the periods he was experiencing mental health issues in relationship to his one-year filing deadline of October 27, 2011. Moreover, the fact that petitioner filed his initial petition only two days after the deadline arguably demonstrates that his mental impairments were likely not so severe that he was unable to understand the need to timely file the petition. See Bills v. Clark, 628 F.3d 1092, 1093 (9th Cir. 2010).
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