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May a federal court equitably toll habeas proceedings under the Antiterrorism and Effective Death Penalty Act prospectively until the capital defendant is deemed competent to proceed? U.S. Supreme Court. Tibbals v. Carter, No. 11-218. Certiorari granted: March 19, 2012. Ruling below: 644 F.3d 329 (6th Cir. 2011).