Bavilla v. Hamilton

CourtDistrict Court, D. Alaska
DecidedMarch 6, 2023
Docket3:22-cv-00286
StatusUnknown

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

Bluebook
Bavilla v. Hamilton, (D. Alaska 2023).

Opinion

FOR THE DISTRICT OF ALASKA

VERNON S. BAVILLA, Petitioner, v. Case No. 3:22-cv-00286-SLG JASON HAMILTON, Superintendent, Palmer Correctional Center, Respondent.

ORDER OF DISMISSAL On December 23, 2022, Vernon S. Bavilla, a self-represented prisoner, filed a Petition Under 28 U.S.C. § 2254 for Writ of Habeas Corpus by a Person in State

Custody (“Petition”).1 Mr. Bavilla also filed a Prisoner’s Application to Waive Prepayment of the Filing Fee, a Financial Affidavit, a Motion for Appointment of Counsel, and Motion for Waiver of Exhaustion Requirement for Petitioner to Pursue 28 U.S.C. § 2254, along with a Notice and Memorandum.2 The Court takes judicial notice3 of Mr. Bavilla’s underlying criminal conviction

in State of Alaska v. Bavilla, Vernon, Case No. 4BE-07-01473CR, and his post-

1 Docket 1. 2 Dockets 2–7. 3 Judicial notice is the “court’s acceptance, for purposes of convenience and without requiring a party’s proof, of a well-known and indisputable fact; the court’s power to accept such a fact.” BLACK’S LAW DICTIONARY (11th ed. 2019); see also Headwaters Inc. v. U.S. Forest Service, 399 F.3d 1047, 1051 n.3 (9th Cir. 2005) (“Materials from a proceeding in another tribunal are No. 4BE-13-00274CI. SCREENING REQUIREMENT A court must “promptly examine” a habeas petition.4 “If it plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief in the district court, the judge must dismiss the petition.”5 Upon screening, it plainly

appears that Mr. Bavilla is not entitled to habeas relief pursuant to Section 2254 and his petition must be dismissed. DISCUSSION Petitions filed under 28 U.S.C. § 2254 must meet strict procedural requirements. A prisoner that is in custody based on a state court conviction

cannot maintain a Section 2254 action until he has first exhausted his state court remedies.6 Exhaustion of state remedies requires a petitioner to fairly present each federal claim to the state courts in order to give the state the opportunity to pass upon and correct any alleged violations of its prisoners' federal rights.7 To satisfy the “fairly present” requirement, a petitioner must present each federal claim

Evid. 201. 4 Rule 4, Rules Governing Section 2254 Proceedings for the United States District Courts. 5 Rule 4, Rules Governing Section 2254 Proceedings for the United States District Courts. 6 28 U.S.C. § 2254(b)(1). 7 Duncan v. Henry, 513 U.S. 364, 365 (1995) (per curium).

Case No. 3:22-cv-00286-SLG, Bavilla v. Hamilton discretionary review)” so that each court is alerted to the federal nature of the claim.8 In Alaska, this means that each federal claim must first be presented to the Alaska Superior Court. If the petitioner disagrees with that result, the claim must then be raised to the Alaska Court of Appeals, and if he disagrees with that result,

the claim must be then raised in a petition for hearing to the Alaska Supreme Court.9 This same process also applies to post-conviction proceedings by the Alaska Superior Court and review of any post-conviction decision by the Alaska Court of Appeals and the Alaska Supreme Court.10 In May 2013, Mr. Bavilla filed an application for post-conviction relief with

the Superior Court in Bethel. On August 13, 2015, the Superior Court dismissed the case. Mr. Bavilla then appealed to the Alaska Court of Appeals at Case No. A-12369.11 The Court of Appeals reversed the Superior Court’s dismissal and remanded Mr. Bavilla’s case.12 The public record shows that the Bethel Superior

8 Baldwin v. Reese, 541 U.S. 27, 29 (2004) (relying on Duncan, 513 U.S. at 365-66.). 9 See O’Sullivan v. Boerkel, 526 U.S. 828, 845. In Alaska, a criminal defendant may request discretionary review by the Alaska Supreme Court. See Alaska Statutes §§ 22.05.010, 22.07.020, and 22.07.030; Alaska Rules of Appellate Procedure 215, 301, and 302. 10 See 28 U.S.C. § 2254(c); see also O’Sullivan, 526 U.S. at 844-45. See generally Alaska R. Crim. P. 35.1. 11 See https://records.courts.alaska.gov. 12 Docket 1-1 at 6.

Case No. 3:22-cv-00286-SLG, Bavilla v. Hamilton hearing was held on February 23, 2023.13 In this Petition, Mr. Bavilla acknowledges that his post-conviction relief claims have not been fully exhausted in the state courts. Instead, he asks for this Court to waive the exhaustion requirement. He asserts that he falls under an exception to the exhaustion requirements due to “inordinate delay.” Specifically,

Mr. Bavilla states that his case is an exception because it has been more than nine years since his initial post-conviction relief application in 2013, his case has been “stuck in limbi” at the Bethel Superior Court, and he is “getting no-where.”14 As noted by Mr. Bavilla, Section 2254(b)(1)(B) provides an exception to the exhaustion requirement when there is (i) an absence of available state corrective

process; or (ii) circumstances exist that render such process ineffective to protect the rights of the applicant.15 In the Ninth Circuit, courts look to four factors in determining whether the state’s delay in adjudicating a petitioner’s claims satisfies either of the § 2254(b)(1)(B) or violates due process: 1) the length of the delay, 2) the reason for the delay, 3) the defendant’s assertion of his right, and 4) prejudice to the defendant.16

13 See https://records.courts.alaska.gov. 14 Dockets 5, 6, 7. 15 28 U.S.C. § 2254(b)(1)(B)(i), (ii). 16 Coe v. Thurman, 922 F.2d 528, 530–31 (9th Cir. 1990) (holding that excessive delay, denying due process, may excuse exhaustion).

Case No. 3:22-cv-00286-SLG, Bavilla v. Hamilton While these cases do show the rare situations where an exception to the exhaustion requirement is warranted, the facts and evidence in Mr. Bavilla’s case are not sufficient to dispense with the exhaustion rule.18 First, Mr. Bavilla asserts that he has suffered a nearly 10-year delay in the state courts regarding his application for post-conviction relief. He initiated his

application for post-conviction relief alleging ineffective assistance of counsel in June 2013 and appealed to the Alaska State Court of Appeals in November 2015. The Court of Appeals decision reversing and remanding the Superior Court’s 2015

17 E.g., Hankins v. Fulcomer, 941 F.2d 246 (3rd Cir. 1991) (the Circuit Court excused exhaustion of state remedies based on inordinate delay of nearly 11 years in deciding Hankins’s motion for withdrawal of guilty plea); Brooks v. Jones, 875 F.2d 30, 31–32 (2nd Cir. 1989) (excused exhaustion when petitioner waited eight years for the appeal of his state criminal convictions to be heard); Doggett v. U.S.. 505 U.S. 647 (1992) (an interval of eight-and-one-half years between defendant’s indictment and his arrest clearly triggered speedy trial inquiry); Rose v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Baldwin v. Reese
541 U.S. 27 (Supreme Court, 2004)
United States v. Jeffery Antoine
906 F.2d 1379 (Ninth Circuit, 1990)
Donald O. Coe v. Otis Thurman, Warden
922 F.2d 528 (Ninth Circuit, 1991)
Victor Turner v. Margaret Bagley
401 F.3d 718 (Sixth Circuit, 2005)
Duncan v. Henry
513 U.S. 364 (Supreme Court, 1995)
Hankins v. Fulcomer
941 F.2d 246 (Third Circuit, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
Bavilla v. Hamilton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bavilla-v-hamilton-akd-2023.