Burkhardt v. Guerrero

CourtDistrict Court, S.D. Texas
DecidedJune 16, 2025
Docket4:25-cv-02189
StatusUnknown

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

Bluebook
Burkhardt v. Guerrero, (S.D. Tex. 2025).

Opinion

□ Southern District of Texas ENTERED June 20, 2025 IN THE UNITED STATES DISTRICT COURT Nathan O chsner, Clerk FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION JEFFREY NORMAN BURKHARDT, § Petitioner, § § v. § CIVIL ACTION NO. H-25-2189 § ERIC GUERRERO, § § Respondent. § MEMORANDUM OPINION AND ORDER Petitioner, a state inmate proceeding pro se and in forma pauperis, filed a habeas petition under 28 U.S.C. § 2254 challenging his 2021 Harris County, Texas conviction and fifteen-year sentence for failure to comply with registration requirements as a convicted sex offender. Having reviewed petitioner’s pleadings, matters of public record, and the applicable law, the Court DISMISSES the petition as barred by limitations. I. BACKGROUND Petitioner pleaded guilty to failure to comply with registration requirements as a convicted sex offender in Harris County, Texas, and was sentenced to a fifteen-year term of imprisonment on September 23, 2021.' No appeal was taken. Petitioner’s application for

‘Petitioner concurrently pleaded guilty to, and received fifteen year sentences for, possession of child pornography and possession of child pornography with intent to promote. Petitioner challenges these other two convictions in separate federal habeas petitions. Burkhardt y. Guerrero, C.A. No. H-25-2088 (S.D. Tex.); Burkhardt v. Guerrero, C.A. No. H-25-1921 (S.D. Tex.).

state habeas relief, filed with the state trial court on November 12, 2024, was denied by the Texas Court of Criminal Appeals on February 5, 2025. Petitioner filed the instant habeas petition no earlier than March 20, 2025, in the United States District Court for the Eastern District of Louisiana. (Docket Entry No. 1.) The petition was properly transferred to this Court on April 14, 2025. As grounds for federal habeas relief, petitioner contends that authorities failed “to read Miranda rights” before questioning him, “charged too much time for felony three charge,” failed to present a warrant for his cell phone, and that trial counsel was ineffective on October 14, 2020, regarding his email address. In explaining why he failed to file his petition prior to expiration of limitations on October 25, 2022, petitioner asserts that two family deaths on May 27 and June 23, 2022 left him “stressed out,” and that he had various medical procedures, laboratory tests, and

concerns on October 25, 2022, November 3, 2022, March 6, 2023, and April 18, 2023, a negative colonoscopy at an unknown date in early 2024, and a positive sleep study for apnea at some point thereafter, for which he was given “a breathing machine” with wrong masks. Il. LEGAL STANDARDS A. Limitations The petition is governed by provisions of the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”). Under AEDPA, federal habeas corpus petitions are subject to a one-year limitations period found in 28 U.S.C. § 2244(d), which provides as follows:

(d)(1) A 1-year period of limitations shall apply to an application for a writ of habeas corpus by a person in custody pursuant to the 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. 28 U.S.C. §§ 2244(d)(1)-(2). A state habeas application filed after limitations has expired does not entitle a petitioner to statutory tolling. Scott v. Johnson, 227 F.3d 260, 263 (Sth Cir.

2000). B. Equitable Tolling The Supreme Court of the United States has made clear that a federal habeas petitioner may avail himself of the doctrine of equitable tolling “only ifhe shows (1) that he

has been pursuing his rights diligently, and (2) that some extraordinary circumstance stood

in his way and prevented timely filing.” McQuiggin v. Perkins, 569 U.S. 383, 391 (2013); Holland v. Florida, 560 U.S. 631, 649 (2010). Equitable tolling is available only in cases presenting “rare and exceptional circumstances,” United States v. Riggs, 314 F.3d 796, 799 (5th Cir. 2002), and is “not intended for those who sleep on their rights.” Manning v. Epps, 688 F.3d 177, 183 (Sth Cir. 2012). The petitioner bears the burden to show that equitable tolling should apply. Alexander

v. Cockrell, 294 F.3d 626, 629 (Sth Cir. 2002). To do so, the petitioner must show that he was pursuing his rights diligently and that some extraordinary circumstance stood in his way and prevented the timely filing of his petition. Holland, 560 U.S. at 649. Equitable tolling applies principally where the petitioner is actively misled by the government or is prevented in some extraordinary way from asserting his rights. Fierro v. Cockrell, 294 F.3d 674, 682

(Sth Cir. 2002). Neither excusable neglect nor ignorance of the law is sufficient to justify equitable tolling. Jd. Lack of legal acumen and unfamiliarity with the legal process are not sufficient justification to toll limitations. United States v. Petty, 530 F.3d 361, 366 (Sth Cir. 2008); Alexander, 294 F.3d at 629. Petitioner acknowledges that his federal petition is untimely, and offers various explanations for his late filing. The Court construes petitioner’s pleadings as claiming entitlement to equitable tolling.

Il. ANALYSIS Public online state court records show that petitioner pleaded guilty to failing to

comply with registration requirements as a convicted sex offender and was sentenced to a

fifteen-year term of imprisonment on September 23, 2021. He did not pursue an appeal. Thus, his conviction became final for purposes of AEDPA limitations no later that October

25, 2021. The one-year statute of limitations expired on October 25, 2022, subject to

statutory tolling. Online state court records show that petitioner’s application for state habeas relief, filed with the trial court on November 12, 2024, was denied by the Texas Court of Criminal Appeals on February 5, 2025. Because the application for state habeas relief was filed after expiration of the federal statute of limitations, the state habeas proceeding did not toll expiration of the AEDPA one-year limitation.’ Petitioner’s instant federal habeas petition, filed no earlier than March 20, 2025, is

untimely.

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Related

Scott v. Johnson
227 F.3d 260 (Fifth Circuit, 2000)
Alexander v. Cockrell
294 F.3d 626 (Fifth Circuit, 2002)
Fierro v. Cockrell
294 F.3d 674 (Fifth Circuit, 2002)
United States v. Riggs
314 F.3d 796 (Fifth Circuit, 2002)
United States v. Petty
530 F.3d 361 (Fifth Circuit, 2008)
McQuiggin v. Perkins
133 S. Ct. 1924 (Supreme Court, 2013)
Willie Manning v. Christopher Epps, Commissioner
688 F.3d 177 (Fifth Circuit, 2012)

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Burkhardt v. Guerrero, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burkhardt-v-guerrero-txsd-2025.