THOYT HACKNEY v. STATE OF MARYLAND
Court of Appeals of Maryland, Barbera, May 9, 2018,
Prison Mailbox Rule – A pro se prisoner’s mailing of a post-conviction is deemed “filed” when formally delivered to prison authorities for mailing to the court

No thoyt jokes, please.
Why are we opening up this can of worms? There’s ALREADY an escape valve for exceptional circumstances built into the statute! Now if a letter is found in the prison mailroom thirty years from now, it was properly filed and a post-conviction should be allowed? The defendant has TEN YEARS to file a post-conviction. Do we have to bend over backwards because he decided to wait 9 years and 363 days to mail it in? It’s not like he explained that “I failed to sufficiently prioritize my personal affairs.”

Facts:
On October 23, 1998, Hackney was sentenced to sixty years after having been convicted by a Baltimore City jury of two counts of second-degree murder.
Absent “extraordinary cause,” a defendant has 10 years to file a post-conviction.
On October 20, 2008, Hackney claims that he signed a certificate of service and gave it to prison officials to mail.
The court did not receive the application until October 24, 2008.
The court dismissed Thoyt’s post-conviction as having been filed outside of the 10-year limit.
Thoyt appealed, arguing that a post-conviction filed from prison should count as being filed when it is given to the prison officials, not when the court receives it.

Held: The Court of Appeals agreed, holding that a defendant representing himself in a post-conviction has 10 years from sentencing to give the mail to prison officials.