Charles Bryant Hughes, Jr. v. Warden Reosha Butler

CourtDistrict Court, M.D. Alabama
DecidedMay 4, 2026
Docket2:25-cv-00952
StatusUnknown

This text of Charles Bryant Hughes, Jr. v. Warden Reosha Butler (Charles Bryant Hughes, Jr. v. Warden Reosha Butler) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charles Bryant Hughes, Jr. v. Warden Reosha Butler, (M.D. Ala. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

CHARLES BRYANT HUGHES, JR., ) ) Petitioner, ) ) v. ) CASE NO. 2:25-CV-952-WKW ) [WO] WARDEN REOSHA BUTLER, ) ) Respondent. )

MEMORANDUM OPINION AND ORDER

I. INTRODUCTION Charles Bryant Hughes, Jr., an Alabama state-convicted prisoner, filed this Petition for Writ of Habeas Corpus Under 28 U.S.C. § 2254 on December 4, 2025.1 (Doc. # 1.2) In this § 2254 petition, as amended (Doc. # 8), Petitioner challenges the constitutionality of his convictions, after a trial by jury, and the 50-year sentence imposed for first-degree rape in violation of Alabama Code § 13A-6-61 and second- degree burglary in violation of Alabama Code § 13A-7-6 in the Circuit Court of Elmore County, Alabama. The sentence consists of a term of 35 years’

1 Petitioner is represented by counsel; hence, the prison mailbox rule is inapplicable. See Williams v. McNeil, 557 F.3d 1287, 1290 n.2 (11th Cir. 2009) (“Under the ‘prison mailbox rule,’ a pro se prisoner’s court filing is deemed filed on the date it is delivered to prison authorities for mailing.”).

2 References to “Doc(s).” are to the document numbers of the pleadings and other materials in the court’s electronic record, as compiled and designated on the docket sheet by the Clerk of Court. Pinpoint citations are to the page of the electronically filed document in the court’s CM/ECF filing system. imprisonment on the rape conviction and 15 years’ imprisonment on the burglary conviction, to be served consecutively. (See Doc. # 16 at 5.) In both direct and

postconviction proceedings, the state courts denied Petitioner relief. (Docs. # 18- 12, 18-14, 18-23, 18-24, 18-26.) In the current § 2254 petition, Petitioner acknowledges that he did not file this

(his first) petition within the one-year limitation period outlined in § 2244(d)(1)(A). (Doc. # 8 at 13.) However, he alleges that § 2244(d) does not bar this petition “on grounds of actual innocence because the charged sexual conducts were consensual.”3 (Doc. # 8 at 13.) Respondent answered arguing, among other things, that the petition

is untimely under 28 U.S.C. § 2244(d)(1)(A). (Doc. # 16.) After two court directives, Petitioner filed a reply raising equitable tolling as an exception to the time-bar and reasserting the actual-innocence gateway.4 (Docs. # 17, 19, 20.)

For the reasons set out below, Petitioner’s claims are time-barred under § 2244(d)(1)(A), and Petitioner has not presented facts justifying equitable tolling

3 The form Petitioner used to file his § 2254 petition contains a section that directs a petitioner whose judgment of conviction became final more than one year earlier to “explain why the one- year statute of limitations as contained in 28 U.S.C. § 2244(d) does not bar [his] petition.” (Doc. # 8 at 13.)

4 The reply brief has been considered, even though it was filed two days after the court-ordered deadline without a motion requesting permission for the untimely filing. or demonstrating a gateway claim of actual innocence so as to excuse the time bar. Therefore, the petition must be dismissed with prejudice.5

II. SUBJECT MATTER JURISDICTION AND VENUE Under 28 U.S.C. § 2254(a), federal district courts have the authority to consider an application for a writ of habeas corpus on behalf of an individual in state

custody pursuant to a state-court judgment but “only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” This provision limits authority, rather than conferring it, with habeas jurisdiction established by 28 U.S.C. § 2241. See Thomas v. Crosby, 371 F.3d 782, 787 (11th

Cir. 2004). Under § 2241, federal district courts have the power to grant writs of habeas corpus “within their respective jurisdictions,” § 2241(a), when a state- convicted prisoner “is in custody in violation of the Constitution, ” § 2241(c)(3).

The “in-custody” requirement mandates that the habeas petitioner must “be ‘in custody’ under the conviction or sentence under attack at the time his petition is filed.” Maleng v. Cook, 490 U.S. 488, 490–91 (1989) (per curiam). Furthermore, § 2241(d), referred to as a “venue provision,” “gives the petitioner ‘the option of

seeking habeas corpus either in the district where he is confined or the district where

5 An evidentiary hearing under 28 U.S.C. § 2254(e)(2) and Rule 8 of the Rules Governing Section 2254 Cases in the United States District Courts is not necessary to adequately dispose of the petition. the sentencing court is located.’” Dobard v. Johnson, 749 F.2d 1503, 1509–10 (11th Cir. 1985) (Clark, J., dissenting) (citation omitted).

Petitioner was in custody under a state-court judgment when he filed this petition. Additionally, at the time of filing, Petitioner was incarcerated for his state offenses in a state prison located in the Middle District of Alabama and was

convicted and sentenced by a state court in this district. Accordingly, this court has subject matter jurisdiction to consider the petition, and venue is proper. III. DISCUSSION A. The AEDPA’s Statute of Limitations

The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), effective April 24, 1996, provides that “[a] 1-year period of limitation shall apply to an application for a writ of habeas corpus by a person in custody pursuant to the

judgment of a State court.” 28 U.S.C. § 2244(d)(1). The one-year period begins to run when the state-court judgment is considered final, as defined by the AEDPA. See Gonzalez v. Thaler, 565 U.S. 134, 150 (2012). The AEDPA specifies two alternative dates on which a state-court judgment becomes final: (1) at the

“conclusion of direct review” or (2) upon the “expiration of the time for seeking such review.” § 2244(d)(1)(A).6

6 The petition contains no facts that would trigger the application of § 2244(d)(1)(B)–(D). In the answer to the amended petition, Respondent outlines the procedural timeline, concluding that after the state court judgment became final and accounting

for periods subject to statutory tolling, see § 2244(d)(2), the one-year limitation period under § 2244(d)(1) expired in January 2024. (Doc. # 16 at 32–34.) Yet, Petitioner waited until December 2025, more than one year and ten months later, to

file this § 2254 petition. (Doc. # 1; Doc. # 16 at 34.) In his reply, Petitioner does not dispute Respondent’s timeline or the petition’s untimeliness under § 2244(d). Instead, he contends that he has made a “credible showing of actual innocence, coupled with a constitutional violation that prevented

the prosecution of that claim.” (Doc.

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