Arnold v. Pennsylvania Parole Board

CourtDistrict Court, M.D. Pennsylvania
DecidedJanuary 24, 2025
Docket1:24-cv-00837
StatusUnknown

This text of Arnold v. Pennsylvania Parole Board (Arnold v. Pennsylvania Parole Board) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arnold v. Pennsylvania Parole Board, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

DALE R. ARNOLD, : Petitioner : : No. 1:24-cv-00837 v. : : (Judge Kane) PENNA PAROLE BOARD, et al., : Respondents :

MEMORANDUM This is a habeas corpus case filed under 28 U.S.C. § 2254 through which pro se Petitioner Dale R. Arnold (“Arnold”), a convicted state inmate serving a life sentence imposed in 1982, seeks to challenge a purported decision by the Pennsylvania Board of Probation and Parole (“Parole Board”) to deny him parole. He also raises additional claims for habeas relief and ultimately seeks his release from incarceration. Arnold has also filed: (1) a motion for appointment of counsel; (2) a “Motion in Support [of] Complaint”; (3) a “Motion for Finalization” in which he appears to claim that he is entitled to the relief sought in his habeas petition because Respondents have not responded to it yet; (4) a motion for summary judgment; (5) a motion for “Permission to Proceed Statement [sic] of the Amount of Damages”; and (6) a motion for “Permission to Proceed for Judicial Review.” For the reasons set forth below, the Court will dismiss the Section 2254 petition, deny as moot Arnold’s motion for appointment of counsel, and deem his other motions withdrawn due to his failure to file a supporting brief in accordance with this Court’s Local Rules. I. BACKGROUND In 1981, a jury sitting in the Court of Common Pleas of Bradford County found Arnold guilty of first-degree murder, theft, and kidnapping. See Commonwealth v. Arnold, 480 A.2d 1066, 1070 (Pa. Super. Ct. 1984); Commonwealth v. Arnold, No. CP-08-CR-0001026-1980 (Bradford Cnty. Ct. Com. Pl. filed Feb. 9, 1990) (showing convictions).1 In May 1982, the trial judge imposed a sentence of life imprisonment. See Arnold, 480 A.2d at 1070. Arnold appealed from his judgment of sentence to the Superior Court of Pennsylvania, which affirmed this judgment on June 29, 1984. See id. at 1080. It appears that Arnold then sought discretionary

relief from the Pennsylvania Supreme Court, which the Court denied. See Arnold v. Frank, No. 00-cv-00775 (M.D. Pa. filed Apr. 28, 2000), ECF No. 1 at 2 (indicating that Arnold filed petition for allowance of appeal with Pennsylvania Supreme Court, which was denied). Arnold’s subsequent collateral-relief challenges in the Pennsylvania state courts were unsuccessful. See id. (listing Arnold’s unsuccessful attempts to obtain post-conviction collateral relief in Pennsylvania state courts). Arnold first sought federal habeas relief by filing a Section 2254 petition on April 28, 2000. See id. Judge J. Andrew Smyser, now retired, issued a report recommending that Arnold’s petition be denied because four (4) of his five (5) claims lacked merit and the remaining claim was procedurally defaulted. See id., ECF No. 43. Although Arnold filed Objections to the

Report and Recommendation, see id., ECF No. 44, this Court overruled those Objections, adopted the Report and Recommendation, and dismissed the habeas petition. See id., ECF No. 47. The Court later denied Arnold’s request for a certificate of appealability. See id., ECF No. 50. Arnold then filed an appeal to the Third Circuit Court of Appeals, see id., ECF No. 51, which denied his application for a certificate of appealability. See Arnold v. Frank, No. 02-4112 (3d Cir. filed May 12, 2003).

1 The Court takes judicial notice of the state court’s docket sheet in Arnold’s criminal case, which is available through the Unified Judicial System of Pennsylvania Web Portal at the following website: https://ujsportal.pacourts.us/CaseSearch. Arnold filed another Section 2254 petition with this Court on November 1, 2022.2 See Arnold v. Warden of SCI-Benner Twp., No. 1:22-cv-01944 (M.D. Pa. filed Nov. 1, 2022). After reviewing the petition pursuant to Rule 4 of the Rules Governing Section 2254 Cases, the Court ordered Arnold to show cause why the Court should not dismiss the petition as untimely. See id.,

ECF No. 6. Arnold filed a response to the Order, see id., ECF. No. 7, and the Court ultimately dismissed the petition as untimely and declined to issue a certificate of appealability. See id., ECF Nos. 8, 9. Arnold then filed a motion for reconsideration, see id., ECF No. 10, which this Court denied through a Memorandum and Order, see id., ECF Nos. 13, 14. Arnold appealed from this decision to the Third Circuit, see id., ECF No. 16, which ultimately denied Arnold’s request for a certificate of appealability, see id., ECF No. 18. While Arnold’s appeal in his second Section 2254 action was pending before the Third Circuit, he filed the instant habeas petition, along with, inter alia, a motion for appointment of counsel, a “Concise Statement of Facts,” and a “Motion in Support [of] Complaint.” (Doc. Nos. 1, 5, 6, 7.) The petition, which is forty-eight (48) pages in length, is not only very difficult to

read, but also consists of a rambling narrative, references to irrelevant legal doctrines and principles, nonsensical legal arguments, and references to facts that have nothing to do with the claims in the habeas petition. See (id. at 1–48). Nevertheless, as best the Court can discern, Arnold appears to primarily claim in his habeas petition that the Parole Board wrongfully denied him parole. See (id. at 1–18, 45, 48).

2 Although the Court did not receive the petition until December 8, 2022, it is deemed filed on November 1, 2022, because Arnold included a letter with the petition seemingly showing that he provided the petition to prison authorities to mailing to the Clerk of Court on that date. See Houston v. Lack, 487 U.S. 266, 276 (1988) (holding that pro se prisoner’s petition is deemed filed “at the time petitioner delivered it to the prison authorities for forwarding to the court clerk”). The Court has also construed Arnold’s habeas petition as containing the following additional claims for habeas relief: (1) his trial counsel was ineffective when he had Arnold agree to a shorter term for a life sentence which Arnold has never received; (2) he received an unlawfully lengthy sentence; (3) he has experienced unlawful conditions of confinement; and (4) the statute

under which he was sentenced is unconstitutionally vague. See (id. at 1–18). Overall, he believes that his rights under the Fourth, Fifth, Sixth, Eighth, and Fourteenth Amendments to the United States Constitution have been violated. (Id. at 1, 4.) Regarding these habeas claims, Arnold alleges that the Parole Board denied him parole when it purportedly informed him that “life means life imprisonment.” See (id. at 18). He asserts that an agreement was reached regarding his sentence when both the “Bradford County Court Staff and [his] attorneys” told him that “life in Penna. is 10-to-12 years in prison, 15 years if you are a bad ass.” See (id. at 2, 3). According to Arnold, this information constituted “[a] stipulation of facts, agreements, [and] promises,” which “must be enforced”; yet, forty-four (44) years later, he remains incarcerated in state prison. See (id. at 2). In support of his claim that an

agreement was reached, he relies on “the Famous Bill Cosby Case,” where the Pennsylvania Supreme Court purportedly determined that “deals, contracts, agreements, [and] a promise from years ago,” must be upheld. See (id. at 3). Additionally, Arnold contends that in Commonwealth v. Miller, 275 A.3d 530 (Pa. Super. Ct. 2022), the Pennsylvania Superior Court “ruled” that life in Pennsylvania “is 35 years” because that is the statutory minimum for first-degree murder. See (id.). He also believes the Pennsylvania General Assembly “intended that life imprisonment . . .

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Arnold v. Pennsylvania Parole Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arnold-v-pennsylvania-parole-board-pamd-2025.