such as a simple miscalculation that leads a lawyer to miss a filing deadline, does not warrant equitable tolling,” id. at 2564 (internal citations and quotation marks omitted), the Eleventh Circuit erred in concluding that “ ‘pure professional negligence’ on the part of a petitioner’s attorney ... can never constitute an ‘extraordinary circumstance’ ” sufficient to justify equitable tolling, id. at 2559 (quoting Helton v. Sec’y for Dep’t of Corrs., 259 F.3d 1310, 1312 (11th Cir.2001); cf. Smaldone v. Senkowski, 273 F.3d 133, 138 (2d Cir.2001)) (stating that attorney error alone is “inadequate to create the ‘extraordinary’ circumstances equitable tolling requires”); Geraci v. Senkowski, 211 F.3d 6, 9 (2d Cir.2000), superseded by statute on other grounds, N.Y.Crim. Proc. Law § 450.90(1) (<HOLDING>). As the Supreme Court has long recognized, the
recognizing that equitable tolling doctrines may toll the time period for filing holding that attorney miscalculation of aedpa time period did not justify equitable tolling holding that the 120day filing period is subject to equitable tolling and addressing circumstances warranting equitable tolling holding that attorneys misunderstanding of the period for which a claim remained pending did not warrant equitable tolling holding that attorneys mental illness may justify equitable tolling