Borns v. Chrisman

CourtDistrict Court, E.D. Michigan
DecidedJuly 25, 2025
Docket2:17-cv-13694
StatusUnknown

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

Bluebook
Borns v. Chrisman, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

CLARENCE BORNS, Case No. 2:17-CV-13694-TGB

Petitioner, Honorable Terrence G. Berg OPINION AND ORDER vs. GRANTING RESPONDENT’S MOTION FOR STAY PENDING TROY CHRISMAN, APPEAL (ECF NO. 41) Respondent. AND GRANTING PETITIONER’S MOTION FOR RELEASE ON BOND PENDING APPEAL (ECF NO. 38)

On March 31, 2025, the Court granted Petitioner Clarence Borns a conditional writ of habeas corpus on the ground that he received ineffective assistance of counsel and the state court’s decision to the contrary was an unreasonable application of clearly established Supreme Court precedent. Borns v. Chrisman, 776 F. Supp.3d 595 (E.D. Mich. 2025). The Court has ordered Petitioner released from state custody unless the State of Michigan initiates proceedings to retry him within 120 days. Id. at 624. Respondent has appealed the Court’s decision (ECF No. 36) and moved for a stay pending appeal (ECF No. 41). Petitioner has moved for bond pending appeal. (ECF No. 38.) I. Legal Standard Federal Rule of Appellate Procedure 23(c) governs Petitioner’s Motion for Bond and Respondent’s Motion for Stay. Rule 23(c) provides that “[w]hile a decision ordering the release of a prisoner is under review, the prisoner must – unless the court or judge ordering the decision … orders otherwise – be released on personal recognizance, with or without surety.” Fed. R. App. P. 23(c). This rule “undoubtedly creates a

presumption” that a successful habeas petitioner should be “release[d] from custody” pending appeal. Hilton v. Braunskill, 481 U.S. 770, 774 (1987). That presumption, however, “may be overcome” upon a sufficient showing by the respondent. Id. When a district court considers whether to release a successful habeas petitioner or to stay an order granting habeas relief pending appeal, the Court should consider “the factors traditionally considered in deciding whether to stay a judgment in a civil case.” Id. at 776. Those

factors, enumerated in Hilton, are:

(1) whether the stay applicant has made a strong showing that he is likely to succeed on the merits; (2) whether the applicant will be irreparably injured absent a stay; (3) whether issuance of the stay will substantially injure the other parties interested in the proceeding; and (4) where the public interest lies. Id. The Supreme Court provided this additional guidance in Hilton: The interest of the habeas petitioner in release pending appeal, always substantial, will be strongest where the [traditional stay] factors … are weakest. The balance may depend to a large extent upon determination of the State’s prospects of success in its appeal. Where the State establishes that it has a strong likelihood of success on appeal, or where, failing that, it can nonetheless demonstrate a substantial case on the merits, continued custody is permissible if the second and fourth factors in the traditional stay analysis militate against release. Where the State’s showing on the merits falls below this level, the preference for release should control. Id. at 777-78 (citations omitted). Finally, “[t]he State’s interest in continuing custody and rehabilitation pending a final determination of the case on appeal is also a factor to be considered; it will be strongest where the remaining portion of the sentence to be served is long, and weakest where there is little of the sentence remaining to be served.” Id. at 777. II. Analysis After weighing the Hilton factors, the Court holds that a stay is warranted. The Court further holds that Petitioner is entitled to release on bond subject to the strict conditions detailed below and in a separately issued order. A. Likelihood of Success on the Merits Respondent contends that he is likely to succeed on the merits of the case on appeal. First, Respondent maintains that the petition was untimely and that Court erred by applying the prison mailbox rule and concluding that the petition was filed within the federal statute of limitations. Second, Respondent argues that Petitioner’s procedural default of his ineffective assistance of counsel claim cannot be excused because appellate counsel reasonably declined to raise this claim. Third, Respondent contends that, even if the default could be excused, the ineffective assistance of trial counsel claim fails on the merits. For the reasons stated in detail in the Court’s order denying Respondent’s motion to dismiss the petition as untimely (ECF No. 25)

and opinion granting habeas relief (ECF No. 30), the Court concludes that Respondent has not demonstrated a strong showing of probable success. This factor, therefore, weighs in Petitioner’s favor. B. Injury to the State Second, the Court must consider potential injury to the State. If the Court’s order requiring either release or a new trial within 120 days is not stayed, the State faces the prospect of expending substantial resources for a second trial while simultaneously appealing the Court’s

decision. This factor favors granting a stay. With respect to the State’s interest in Petitioner’s continued incarceration, the Court must consider both his risk of flight and any potential danger to the community. Respondent opposes release based on the nature of Petitioner’s underlying offense. (ECF No. 15, PageID.7113.) Although Petitioner’s criminal history dates to 1990, none of his prior convictions involve violent offenses. There is, however, an outstanding warrant for Petitioner in the 43rd District Court (Madison Heights), where he was charged with carrying a weapon with unlawful intent and failed to appear for arraignment. Petitioner’s institutional record does not raise significant concerns. Since his incarceration for this offense, he has received five misconduct tickets, but none involving violent behavior. The Court may also consider the length of Petitioner’s remaining sentence. “The State’s interest in continuing custody … will be strongest

where the remaining portion of the sentence to be served is long, and weakest where there is little of the sentencing remaining to be served.” Hilton, 481 U.S. 777. Petitioner’s earliest release date is February 21, 2035, leaving approximately ten years on his minimum sentence. His maximum discharge date is February 21, 2045. In sum, Petitioner’s institutional record does not suggest a risk of violence, and aside from his current offense, his criminal history does not reflect a pattern of violent behavior. Petitioner’s failure to appear on the

outstanding warrant can be addressed through strict conditions of release requiring Petitioner to resolve all outstanding warrants. Failure by Petitioner to comply with this condition may result in his bond being revoked. Moreover, Petitioner appears to have strong family support. After considering all of these arguments, the Court concludes that the Respondent’s legitimate concerns can be adequately addressed by the imposition of a very strict set of release conditions (described in detail below). Thus, the Court concludes that this factor does not weigh in favor of continuing Petitioner’s detention. C. Injury to Other Interested Parties The third Hilton factor considers “whether issuance of the stay will substantially injure the other parties interested in the proceeding.” Hilton, 481 U.S. at 776. When evaluating this factor, courts typically consider whether the habeas petitioner will be irreparably injured by a stay and/or by continued confinement. See, e.g., Pouncy v. Palmer, 168

F. Supp. 3d 954, 969 (E.D. Mich 2016).

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Related

Hilton v. Braunskill
481 U.S. 770 (Supreme Court, 1987)
Burdine v. Johnson
87 F. Supp. 2d 711 (S.D. Texas, 2000)
Pouncy v. Palmer
168 F. Supp. 3d 954 (E.D. Michigan, 2016)
Newman v. Metrish
300 F. App'x 342 (Sixth Circuit, 2008)

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Bluebook (online)
Borns v. Chrisman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/borns-v-chrisman-mied-2025.