Bailey v. Morgan

CourtDistrict Court, S.D. Alabama
DecidedSeptember 9, 2024
Docket1:23-cv-00358
StatusUnknown

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

Bluebook
Bailey v. Morgan, (S.D. Ala. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISON

PAUL EUGENE BAILEY, # 171480, * * Petitioner, * * vs. * CIVIL ACTION NO. 23-00358-JB-B * PHYLLIS MORGAN, * * Respondent. *

REPORT AND RECOMMENDATION

Petitioner Paul Eugene Bailey (“Bailey”), an Alabama state prisoner in the custody of Respondent, has petitioned this Court for federal habeas corpus relief pursuant to 28 U.S.C. § 2254. The District Judge assigned to this case referred Bailey’s petition to the undersigned Magistrate Judge for consideration and recommendation pursuant to 28 U.S.C. § 636(b)(1)(B), S.D. Ala. GenLR 72(a)(2)(R), and Rule 8(b) of the Rules Governing Section 2254 Cases. The undersigned has reviewed the parties’ filings and exhibits and finds there is sufficient information before the Court to resolve the issues presented without an evidentiary hearing.1

1 Because Bailey filed his federal habeas corpus petition after April 24, 1996, this case is governed by the Antiterrorism and Effective Death Penalty Act (“AEDPA”). “AEDPA expressly limits the extent to which hearings are permissible, not merely the extent to which they are required.” Kelley v. Sec’y for Dep’t of Corr., 377 F.3d 1317, 1337 (11th Cir. 2004). Bailey has failed to establish that an evidentiary hearing is warranted in this case. See Birt v. Montgomery, 725 F.2d 587, 591 (11th Cir. 1984) (en banc) (“The burden is on the petitioner in a habeas corpus proceeding to establish the need for an evidentiary hearing.”). For the reasons set forth below, the undersigned RECOMMENDS that Bailey’s § 2254 habeas petition be DISMISSED with prejudice as time-barred pursuant to 28 U.S.C. § 2244(d)(1). I. BACKGROUND This matter arises from the 1994 rape of a 58-year-old woman

in her home. (Doc. 8-15 at 1-2). Following the attack, a sexual assault examination was performed, and evidence was preserved in a rape kit and transported to a laboratory of the Alabama Department of Forensic Sciences (“DFS”) for testing. (Id. at 2). Testing recovered seminal fluid and semen. (Id.). Because DFS did not have a suspect’s DNA to which it could compare the collected DNA, the case languished as a “cold case” until 2015, when additional DNA testing was performed. (Doc. 8-9 at 189; Doc. 8-15 at 2). That testing revealed that the DNA recovered from the rape kit matched Bailey’s DNA profile. (Doc. 8-9 at 189-92). On April 29, 2016, a grand jury in Mobile County, Alabama indicted Bailey for first-degree rape in violation of Alabama Code

§ 13A-6-61(a)(1). (Doc. 8-1 at 45). The case was tried before a jury, which found Bailey guilty on January 10, 2018. (Doc. 8-5 at 11; Doc. 8-10 at 88-91). The court sentenced Bailey to life without the possibility of parole as a habitual offender on March 8, 2018. (Doc. 8-10 at 107-08). Bailey appealed his conviction and sentence to the Alabama Court of Criminal Appeals. (Docs. 8-12, 8-14). On direct appeal, Bailey, through his appellate counsel, argued that: (1) denial of his motion for a continuance resulted in the denial of due process and a fair and impartial trial by leaving his defense counsel with only six days to prepare for trial, which rendered counsel ineffective; (2) denial of a continuance resulted in a

fundamentally unfair trial because it prevented Bailey from obtaining a necessary expert witness; (3) a missing link in the chain of custody rendered the DNA evidence inadmissible; and (4) there was insufficient evidence to support a conviction. (Doc. 8- 12). On March 1, 2019, the Alabama Court of Criminal Appeals issued an unpublished memorandum opinion affirming Bailey’s conviction and sentence. (Doc. 8-15). Bailey did not file an application for rehearing in the Alabama Court of Criminal Appeals or a petition for writ of certiorari in the Alabama Supreme Court, and the Alabama Court of Criminal Appeals issued a certificate of judgment on March 20, 2019. (Doc. 8-16). On October 24, 2019, Bailey filed a pro se motion labeled

“Exclusionary Rule Violation” in the Mobile County Circuit Court. (Doc. 8-17 at 12-23). The circuit court denied Bailey’s motion on November 5, 2019. (Id. at 25). Bailey appealed the denial of his “Exclusionary Rule Violation” motion to the Alabama Court of Criminal Appeals on November 22, 2019. (Id. at 26-27). On May 20, 2020, the Alabama Court of Criminal Appeals reversed and remanded the case with instructions for the circuit court to set aside its earlier ruling and treat Bailey’s “Exclusionary Rule Violation” motion as a Rule 32 petition for postconviction relief. (Doc. 8-22). On May 26, 2020, the circuit court set aside its prior denial and directed the Clerk to docket Bailey’s “Exclusionary Rule

Violation” motion as a Rule 32 petition. (Doc. 8-24 at 63). Bailey subsequently filed another pro se motion which the circuit court treated as a Rule 32 petition. (Id.). The circuit court also appointed counsel to represent Bailey during the Rule 32 process, due to his indigent status. (Id.). Despite being represented by counsel, Bailey filed yet another pro se Rule 32 petition on June 16, 2020. (See id. at 32-61, 63-64). Bailey’s Rule 32 counsel and the circuit court construed Bailey’s Rule 32 petitions to make the following claims: (1) his DNA sample was illegally obtained; (2) the DNA evidence was inadmissible because of a missing link in the chain of custody; (3) the evidence was insufficient to support his conviction; (4) he was denied a DNA

expert; and (5) the trial court was without jurisdiction because of illegally obtained evidence. (Doc. 8-25 at 16, 18-20; Doc. 8- 26 at 70). On November 11, 2021, the circuit court dismissed Bailey’s Rule 32 petition. (Doc. 8-26 at 70-77). Bailey appealed the dismissal of his Rule 32 petition on November 16, 2021. (Id. at 87). On appeal, Bailey’s appointed appellate counsel filed a no-merit brief pursuant to Anders v. California, 386 U.S. 738 (1967), and Bailey filed a pro se statement of issues. (Docs. 8-27, 8-28). Though the Alabama Court of Criminal Appeals found Bailey’s pro se Rule 32 petition and amendments “disjointed and confusing,” it found that Bailey had raised the following claims: (1) his DNA profile was unlawfully

obtained without a warrant and without probable caused from the combined DNA index system (“CODIS”) and illegally compared to the DNA evidence from the victim’s rape kit; (2) there was a missing link in the chain of custody of the rape kit; (3) the State suppressed the fact that his DNA profile was unlawfully obtained, in violation of Brady v. Maryland, 373 U.S. 83 (1963); (4) false evidence was presented at trial, specifically, evidence that the administrator of CODIS matched his DNA to the DNA in the victim’s rape kit in September 2014, before the police had given the rape kit to DFS for testing in January 2015; (5) the evidence was insufficient to sustain his conviction; (6) he was denied a DNA expert to challenge the reliability of the DNA evidence; (7) the

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Bailey v. Morgan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bailey-v-morgan-alsd-2024.