Banks v. Director, TDCJ-CID

CourtDistrict Court, N.D. Texas
DecidedJanuary 15, 2025
Docket1:24-cv-00012
StatusUnknown

This text of Banks v. Director, TDCJ-CID (Banks v. Director, TDCJ-CID) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Banks v. Director, TDCJ-CID, (N.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS ABILENE DIVISION HOLSTON BANKS, III, Petitioner, V. No. 1:24-CV-00012-H DIRECTOR, TDCJ-CID, Respondent. OPINION AND ORDER Petitioner Holston Banks, III, a self-represented state prisoner, filed this petition for writ of habeas corpus under 28 U.S.C. § 2254 to challenge his conviction and 60-year sentence for burglary of a habitation. Respondent filed an answer with copies of Petitioner's relevant state-court records, arguing that the petition is untimely and, alternatively, that it is partially unexhausted and procedurally barred, and otherwise without merit. Dkt. No. 12, 13. Petitioner filed a reply. Dkt. No. 15. He also filed a motion to stay and abey his federal petition to allow him to present his unexhausted claims to the state court. Dkt. No. 14. As explained below, the Court denies Petitioner’s motion to stay and concludes that the petition is untimely, partially unexhausted and procedurally barred, and without merit. I. Background A Howard County jury found Petitioner guilty of burglary of a habitation with intent to commit aggravated robbery (and with a deadly weapon) on November 9, 2018, and sentenced him to 60 years in prison. The Eleventh Court of Appeals affirmed his conviction, and the Texas Court of Criminal Appeals (TCCA) refused his petition for discretionary review. He did not file a petition for writ of certiorari in the Supreme Court.

Petitioner filed a state application for writ of habeas corpus on April 11, 2022, but the Texas Court of Criminal Appeals (TCCA) denied it on September 28, 2022 without written order on the findings of the trial court without a hearing and on the court’s independent review of the record. Petitioner filed this federal habeas action on January 19, 2024.' He later filed an amended petition. Dkt. No. 7. The Court understands Petitioner to challenge his conviction and sentence on these grounds: 1) His Fourth Amendment rights were violated when his DNA was taken pursuant to an invalid warrant; 2) The prosecutor withheld requested discovery until after trial began in violation of Brady v. Maryland; 3) Law enforcement included his photo in a suggestive photo array during the investigation and the witness did not select him; 4) The State offered or relied on false testimony when an [D-technician witness testified inconsistently with her prior report; 5) The State offered or relied on false evidence when the [D-technician witness testified inconsistently with her prior report; 6) He received ineffective assistance of counsel from his pretrial, trial, and appellate attorneys; and 7) The trial judge abused his discretion by presiding over Petitioner’s case even though he was biased and had a conflict of interest. Dkt. No. 7.

‘Petitioner initiated this civil action by filing a motion for an extension of time to file a federal habeas petition. Dkt. No. 1. Because the motion included at least one ground for federal habeas relief, the Court construed the motion as a habeas petition. Ordinarily, prisoners receive the benefit of the prison-mailbox rule. See Spotville v. Cain, 149 F.3d 374, 378 (Sth Cir. 1998) (providing that a prisoner’s habeas petition is deemed to be filed when he delivers the papers to prison authorities for mailing). But here, Petitioner did not deliver his motion to the prison authorities for mailing—it was mailed by a family member from a private residential address. Thus, the papers were not filed until they were received and docketed by the Clerk on January 19, 2024.

Respondent argues that the Court should deny Petitioner’s claims and dismiss the petition with prejudice because it is barred by the applicable statute of limitations. Dkt. No. 12. Alternatively, Respondent argues that some of Petitioner’s claims are unexhausted and procedurally barred and the remainder fail to overcome Section 2254’s relitigation bar. Id. Thus, Respondent argues that even if the petition were timely, Petitioner is not entitled to federal habeas relief. Jd. Petitioner filed a reply, in which he adds a new eighth ground for relief—a freestanding actual-innocence claim purportedly based on newly discovered evidence. Dkt. No. 15. He argues that he is “an innocent man,” his case should not be time-barred, and the Court should “[a]t least remand these issues back to the trial court to reconsider.” Jd. at 14. He also contends that his actual-innocence claim constitutes cause and prejudice sufficient to overcome any procedural bars that apply to his claims. Jd. at 9-10. And he filed a motion requesting to stay this federal action and hold his petition in abeyance so that he may present his unexhausted claims to the state court. Dkt. No. 14. The Court denies the motion to stay as futile because, as explained below, the petition is time barred, partially unexhausted and procedurally barred, and otherwise without merit. 2. Discussion The Court has reviewed Petitioner’s pleadings, Respondent’s answer, and the state court records submitted by Respondent. The Court finds that an evidentiary hearing is not necessary to resolve the instant petition. See Young v. Herring, 938 F.2d 543, 560 n.12 (Sth Cir. 1991) (explaining that “a petitioner need not receive an evidentiary hearing if it would not develop material facts relevant to the constitutionality of his conviction”).

A. Petitioner’s claims are time barred. i. Statute of Limitations Petitioner’s petition is subject to review under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). AEDPA establishes a one-year limitation on filing federal habeas corpus petitions. Specifically, 28 U.S.C. § 2244(d) provides: (1) A 1-year period of limitation shall apply to an application for a writ of habeas corpus by a person in custody pursuant to a judgment of a State court. The limitation period shall run from the latest of — (A) the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review; (B) the date on which the impediment to filing an application created by State action in violation of the Constitution or laws of the United States is removed, if the applicant was prevented from filing by such State action; (C) the date on which the constitutional right asserted was initially recognized by the Supreme Court, if the right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review; Or (D) the date on which the factual predicate of the claim or claims presented could have been discovered through the exercise of due diligence. (2) The time during which a properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim is pending shall not be counted toward any period of limitation under this subsection. ii. Relevant Timeline It is undisputed that Petitioner’s conviction became final on September 20, 2021, when his time for filing a petition for writ of certiorari expired. Thus, absent any tolling, Petitioner’s federal petition was due one year later, on September 20, 2022. Petitioner’s state habeas application was properly filed and tolled the limitations period for 171 days, making his federal petition due on March 10, 2023. But Petitioner did not file his federal petition until January 19, 2024—more than ten months late.

iii. | Equitable Tolling In “rare and exceptional circumstances,” the doctrine of equitable tolling may preserve a petitioner’s claims when the strict application of the statute of limitations would be inequitable. Davis v. Johnson,

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116 F.3d 1115 (Fifth Circuit, 1997)
Spotville v. Cain
149 F.3d 374 (Fifth Circuit, 1998)
Whitehead v. Johnson
157 F.3d 384 (Fifth Circuit, 1998)
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Busby v. Dretke
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In Re Swearingen
556 F.3d 344 (Fifth Circuit, 2009)
Stroman v. Thaler
603 F.3d 299 (Fifth Circuit, 2010)
Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Stone v. Powell
428 U.S. 465 (Supreme Court, 1976)
Anderson v. Harless
459 U.S. 4 (Supreme Court, 1982)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Castille v. Peoples
489 U.S. 346 (Supreme Court, 1989)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Estelle v. McGuire
502 U.S. 62 (Supreme Court, 1991)
Herrera v. Collins
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Schlup v. Delo
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Bluebook (online)
Banks v. Director, TDCJ-CID, Counsel Stack Legal Research, https://law.counselstack.com/opinion/banks-v-director-tdcj-cid-txnd-2025.