Seventh Circuit -- Elliot Ray v. Marc Clements

"Prison mailbox rule" applies to toll AEDPA one year SOL for purposes of a Wisconsin state filing.  (Private prison, incidentally, though apparently not discussed- quick skim)

(Long read.)

Prisoner has burden of production, but state must still carry ultimate burden, despite the fact that it's an affirmative defense.

Concur/dissent:

Petitioner should bear ultimate burden on the affirmative defense

No clear error in lower court decision contrary on merits.

Elliot Ray v. Marc Clements