The Houston Chronicle reported Thursday that Brandley last week learned his claim over improper imprisonment came too late. Brandley's request also lacked a pardon or a court ruling declaring him innocent.
Brandley was released from death row in 1990 after an appeals court ruled he did not get a fair trial and threw out his conviction for the slaying of Cheryl Dee Fergeson at Conroe High School during a volleyball tournament. Brandley was a janitor.
His lawyers claimed racism. The teen was white. Brandley is black.
Prosecutors later dropped charges against Brandley.