Bonilla-Rivera v. Secretary, Department of Corrections (Manatee)

CourtDistrict Court, M.D. Florida
DecidedFebruary 12, 2025
Docket8:24-cv-00799
StatusUnknown

This text of Bonilla-Rivera v. Secretary, Department of Corrections (Manatee) (Bonilla-Rivera v. Secretary, Department of Corrections (Manatee)) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bonilla-Rivera v. Secretary, Department of Corrections (Manatee), (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

MIGUEL BONILLA-RIVERA, Petitioner,

v. Case No. 8:24-cv-799-KKM-AEP

SECRETARY, DEPARTMENT OF CORRECTIONS, Respondent. _______________________________ ORDER Bonilla-Rivera, a Florida prisoner, filed a pro se Petition for Writ of Habeas Corpus under 28 U.S.C. § 2254. (Doc. 1.) Upon consideration of the petition, ( .), the response opposing the petition as time-barred, (Doc. 5), and Bonilla-Rivera’s reply, (Doc. 7), the petition is dismissed as time-barred. Because reasonable jurists would not disagree, a certificate of appealability also is not warranted. I. INTRODUCTION Bonilla-Rivera pleaded nolo contendere to ten counts of possession of child pornography and one count of promoting the sexual performance of a child. (Doc. 6-2, Ex. 1, p. 65.) He received an overall sentence of 30 years in prison, followed by 10 years on sex offender probation. ( ., pp. 59-63, 69-77.) e state appellate court per curiam affirmed the convictions and sentence. (Doc. 6-2, Ex. 6.) Bonilla-Rivera moved for postconviction relief under Florida Rule of Criminal

Procedure 3.850. (Doc. 6-2, Ex. 8, pp. 1-18.) e state trial court denied relief, and the state appellate court per curiam affirmed. (Doc. 6-2, Ex. 8, pp. 275-92; Doc. 6-2, Ex. 11.) e state appellate court dismissed as untimely Bonilla-Rivera’s petition alleging ineffective

assistance of appellate counsel filed under Florida Rule of Appellate Procedure 9.141. (Doc. 6-2, Exs. 13 & 14.) II. ANALYSIS

e Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) governs this proceeding. , 574 F.3d 1354, 1364 (11th Cir. 2009). Under the AEDPA, a federal habeas petitioner has a one-year period to file a § 2254 petition. is

limitation period begins running on the later of “the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review.” 28 U.S.C. § 2244(d)(1)(A). It is tolled for the time that a “properly filed application

for State post-conviction or other collateral review” is pending in state court. 28 U.S.C. § 2244(d)(2). A. e Petition’s Untimeliness under § 2244(d)(1)(A)

e state appellate court affirmed Bonilla-Rivera’s convictions and sentence on September 30, 2020. (Doc. 6-2, Ex. 6.) His judgment became final 90 days later, on December 29, 2020, upon expiration of the time to petition the Supreme Court of the United States for a writ of certiorari. , 309 F.3d 770, 774 (11th Cir.

2002). Bonilla-Rivera had until December 29, 2021, absent statutory tolling, to file his § 2254 petition. Bonilla-Rivera did not file any tolling motions in state court on or before

the December 29, 2021 deadline. us, the AEDPA limitation period expired well before Bonilla-Rivera filed his § 2254 petition on March 20, 2024. e postconviction motion that Bonilla-Rivera filed in state court on September 13, 2022, after the AEDPA limitation

period expired, did not revive that period. (Doc. 6-2, Ex. 8, p. 1); , 255 F.3d 1331, 1333 (11th Cir. 2001) (“[A] state court petition . . . that is filed following the expiration of the federal limitations period ‘cannot toll that period because there is no

period remaining to be tolled.’ ” (quoting , 199 F.3d 1256, 1259 (11th Cir. 2000))). Accordingly, Bonilla-Rivera’s § 2254 petition is untimely under § 2244(d)(1)(A). B. Equitable Tolling

Bonilla-Rivera contends that he is entitled to equitable tolling. Section 2244(d) “is subject to equitable tolling in appropriate cases.” , 560 U.S. 631, 645 (2010). A petitioner is entitled to equitable tolling “only if he shows ‘(1) that he has been

pursuing his rights diligently, and (2) that some extraordinary circumstance stood in his way’ and prevented timely filing” of his § 2254 petition. . at 649 (quoting , 544 U.S. 408, 418 (2005)). “[T]he burden of proving circumstances that justify the application of the equitable tolling doctrine rests squarely on the petitioner,” and

“[m]ere conclusory allegations are insufficient to raise the issue of equitable tolling.” , 633 F.3d 1257, 1268 (11th Cir. 2011). A petitioner must “show a causal connection between the alleged extraordinary circumstances and the late filing of the

petition.” . at 1267. Because this is a “difficult burden” to meet, the Eleventh Circuit “has rejected most claims for equitable tolling.” ., 362 F.3d 698, 701 (11th Cir.

2004); , 340 F.3d 1219, 1226 (11th Cir. 2003) (“[E]quitable tolling applies only in truly extraordinary circumstances.”); , 219 F.3d 1298, 1300 (11th Cir. 2000) (“Equitable tolling is an extraordinary remedy which is typically

applied sparingly.”). e applicability of equitable tolling depends on a case’s facts and circumstances. , 560 U.S. at 649-50 (stating that equitable tolling decisions are made on a case-by-case basis); , 292 F.3d 709, 711 (11th Cir. 2002)

(stating that for purposes of equitable tolling, “[e]ach case turns on its own facts”). Bonilla-Rivera asserts that the law firm he hired to file his state postconviction motion showed “blatant neglect” by failing to file the motion in time to toll the AEDPA

limitation period under § 2244(d)(2). (Doc. 1, p. 9.) Bonilla-Rivera alleges that he retained the firm “in July of 2019, which was eight months prior to the Public Defender’s submission of the direct appeal initial brief.” (Doc. 7, p. 4.) He alleges that the firm “passed responsibility for the case from Attorney to Attorney to Attorney for over three years before

finally submitting a pathetic postconviction motion on September 13, 2022, which was 256 days after the expiration of [his] AEDPA one year time limit.” ( .) Bonilla-Rivera alleges that one of the attorneys mentioned “federalizing” his postconviction claims, and that “early

stage legal teleconferences” with attorneys from the firm “led [him] to believe that they would protect his Federal time which equates to bad faith and dishonesty.” ( ., pp. 5-6.) Bonilla-Rivera is not entitled to equitable tolling. First, Bonilla-Rivera has not

shown that he diligently pursued the timely filing of his § 2254 petition. Bonilla-Rivera alleges that he was aware, at an “early stage” of the attorney-client relationship, of a federal habeas deadline. But Bonilla-Rivera does not allege that he asked anyone at the law firm

about the AEDPA filing deadline or whether the postconviction motion needed to be filed earlier to meet the deadline, or that he took other actions to seek the timely filing of his § 2254 petition. , , 560 U.S. at 653-54 (holding that the petitioner exercised

the necessary diligence when, among other acts, he repeatedly wrote letters to his attorneys concerning the limitation period and attempted to remove his attorney, who misunderstood the deadline, by contacting various courts and the Florida Bar); , 633 F.3d at

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