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The case of John A. Pace v. David DiGuglielmo, Superintendent, State Correctional Institution at Graterford et al., 2004 revolves around the issue of habeas corpus petitions and the one-year statute of limitations for filing such a petition as set by the Antiterrorism and Effective Death Penalty Act (AEDPA). The petitioner, John A. Pace, was a state prisoner who had filed his federal habeas corpus petition late because he mistakenly believed that his time to file would not begin until after the Pennsylvania Supreme Court denied review of his Post Conviction Relief Act (PCRA) appeal. The District Court dismissed his petition as untimely but on appeal, it was held that statutory tolling applied due to "extraordinary circumstances" beyond Pace's control which made it impossible for him to file on time. However, this decision was reversed by the U.S Supreme Court in a unanimous opinion written by Justice Breyer stating that ignorance or misunderstanding about legal processes does not constitute an extraordinary circumstance warranting equitable tolling under AEDPA.
The dissenting opinion in the case of John A. Pace v. David DiGuglielmo, Superintendent, State Correctional Institution at Graterford et al., argued that the majority's decision to apply a statute of limitations on habeas corpus petitions from prisoners who claim they are innocent was incorrect. The dissenters believed this ruling contradicted previous Supreme Court decisions which established that actual innocence claims should not be barred by procedural obstacles like time limits. They also pointed out that Congress did not explicitly include a statute of limitations for these types of claims when it passed the Antiterrorism and Effective Death Penalty Act (AEDPA). Therefore, they felt it was inappropriate for the court to impose one now. Furthermore, they expressed concern about how this decision could potentially lead to wrongful convictions being upheld simply because an inmate filed their petition too late.