In Virginia, until 2001, neither a lower court, nor any other court, could review new evidence after 21 days. In 2001, an exception was made for DNA evidence. In 2004, an exception was made for evidence that could not possibly have been discovered within 21 days, that would have led any "reasonable" person to a verdict of innocent, for people who pled innocent. See http://www.vadp.org/21day.htm, http://truthinjustice.org/VAevidence.htm .