Coleman v. McConahay

CourtDistrict Court, N.D. Ohio
DecidedSeptember 20, 2022
Docket5:21-cv-01985
StatusUnknown

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

Bluebook
Coleman v. McConahay, (N.D. Ohio 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

JOHN C. COLEMAN, CASE NO. 5:21-CV-01985

Petitioner, DISTRICT JUDGE CHARLES ESQUE FLEMING

vs. MAGISTRATE JUDGE AMANDA M. KNAPP

WARDEN TIM MCCONAHAY, ORDER Respondent.

I. INTRODUCTION Petitioner John C. Coleman (“Petitioner”) filed his Petition for Habeas Corpus pursuant to 28 U.S.C. § 2254 (“Petition”) pro se on September 15, 2021.1 (ECF Doc. 1.) He supplemented his Petition on October 22, 2021 with a copy of the Ohio Court of Appeals’ May 6, 2020 decision affirming his convictions on two counts of burglary. (ECF Doc. 3.) This Order addresses the following motions and related filings: • Petitioner’s Motion for Discovery on Behalf of Petitioner and Motion for Evidentiary Hearing (ECF Doc. 18);

• Petitioner’s Motion to Strike (ECF Doc. 23);

• Petitioner’s Amended Claims (Actual Innocence Notice) (ECF Doc. 24);

1 “Under the mailbox rule, a habeas petition is deemed filed when the prisoner gives the petition to prison officials for filing in the federal courts.” Cook v. Stegall, 295 F.3d 517, 521 (6th Cir. 2002) (citing Houston v. Lack, 487 U.S. 266, 273 (1988)). The Petition was docketed on October 20, 2021. (ECF Doc. 1.) • Petitioner’s Emergency Motion to Expand the Record (ECF Doc. 25);

• Petitioner’s Motion to Strike (ECF Doc. 29);

• Petitioner’s Motion to Strike Doc #27, with Motion to Take Judicial Notice of Amended Claims and Vacate Magistrate (ECF Doc. 32);

• Petitioner’s Reply to Respondent Doc #28 with Motion to Apply Mailbox Rule (ECF Doc. 34);

• Petitioner’s Motion for Definite Statement from Respondent (ECF Doc. 36);

• Petitioner’s Motion to Expanding the Record (ECF Doc. 38);

• Petitioner’s Notice of Abuse of Taking of Legal Mail (ECF Doc. 39);

• Petitioner’s Motion for Issuance of Subpoenas to Meet Actual Innocence (Expand Record Demand) (ECF Doc. 42);

• Petitioner’s Motion to Strike Transcripts (ECF Doc. 45);

• Petitioner’s Emergency Request for Appointment of Counsel (ECF Doc. 46);

• Petitioner’s Emergency Motion for Case Docket with Motion to Provide Clarification on Coleman’s Definite Statement Request (ECF Doc. 47);

• Petitioner’s Motion for Issuance of Subpoenas to Meet Actual Innocence Support (Expand Record Request) (ECF Doc. 51);

• Petitioner’s Motion for Issuance of Subpoenas Transcripts (Expand Record Request) (ECF Doc. 52); and

• Petitioner’s Motion for Subpoena the Entire Surveillance Video in Count One Burglary in Support of Actual Innocence Claim (Expand Record Request) (ECF Doc. 56).

The Court’s analysis and disposition of the above matters is set forth below. II. ANALYSIS A. Petitioner’s Amended Petition and Motions to Strike Return of Writ, Apply Mailbox Rule, and Vacate Magistrate Judge Assignment (ECF Docs. 23, 24, 32, 34.)

Although filed separately, the Court addresses Petitioner’s Amended Claims (ECF Doc. 24), Motion to Strike (ECF Doc. 23), Motion to Strike Doc #27, with Motion to Take Judicial Notice of Amended Claims and Vacate Magistrate (ECF Doc. 32), and Motion to Apply Mailbox Rule (ECF Doc. 34) together due to the interrelatedness of the arguments presented therein. In March 2022, Petitioner filed a Motion to Strike, seeking to strike Respondent’s February 24, 2022 Return of Writ. (ECF Doc. 23.) In support, he asserted that Respondent had not served him with the Return of Writ, and that he had only learned of the filing by calling the Clerk’s office. (Id. at p. 1.) The certificate of service date on the motion was March 2, 2022, but it was docketed on March 10, 2022. (Id. at p. 2.) Respondent opposed the Motion, arguing that Respondent “served the Answer/Return of Writ, Exhibits, and Transcripts on Coleman on February 24, 2022 as stated in the Warden’s certificate of service.” (ECF Doc. 27 p. 1.) Respondent further noted that he re-served Petitioner with the filings on March 17, 2022, along with his brief in opposition to the motion. (Id.) Petitioner later filed a document captioned “Petitioner’s Amended Claims,” which appears to set forth seven grounds for relief in connection with the pending habeas petition. (ECF Doc. 24 (“Amended Petition”).) The Petition itself sets forth only five grounds for relief.

(ECF Doc. 1.) The Amended Petition contains a certificate of service dated February 21, 2022, along with a hand-written note on the first page stating: “MAILBOX RULE 2•21•22,” but was docketed on March 14, 2022. (ECF Doc. 24 pp. 1, 3.) The certificate of service states that a “copy of [the] amendment” was mailed to Respondent on February 21, 2022. (Id. at p. 3.) Respondent filed an opposition to the Amended Petition on March 24, 2022, noting that Respondent had filed his Return of Writ on February 24, 2022, and arguing that Petitioner could not amend his Petition without seeking leave of court. (ECF Doc. 28.) Respondent also argued that the Court should not grant Petitioner leave to amend because “there was an undue delay in

raising the claims, amendment would be futile, and the Warden would be unduly prejudiced if Coleman is allowed to amend his petition.” (ECF Doc. 28.) In reply to Respondent’s opposition brief, Petitioner requested that the Court apply the mailbox rule based on the certificate of service date on each of his filings, including his Amended Petition. (ECF Doc. 34.) He argued “the record will confirm that Coleman’s Doc. No 24 [Petitioner’s Amended Claims] was filed after he requested to strike respondent answer / return of writ for lack of service” if the mailbox rule is applied. (Id.at p. 1.) He also asserted that Respondent would not be prejudiced if he were allowed to amend his Petition. (Id. at p. 2.) This reply brief was docketed on April 11, 2022, with a certificate of service dated March 29, 2022. (Id.)

Petitioner also filed a Motion to Strike Doc #27, with Motion to Take Judicial Notice of Amended Claims and Vacate Magistrate (Actual Innocence Notice), which was docketed on April 4, 2022. (ECF Doc. 32.) The certificate of service is dated March 26, 2022 and a hand- written note on the first page states: “MAILBOX RULE.” (Id. at pp. 1, 3.) In this motion, Petitioner requested that Respondent’s opposition to his Motion to Strike Return of Writ (ECF Doc. 27) be stricken because the Respondent attempted to re-serve him with the Answer / Return of Writ without first seeking leave of Court, and asserted that no Exhibits or Transcripts accompanied the newly served Return of Writ. (Id. at p. 2.) He also requested that the Court apply the mailbox rule to all filings, take judicial notice of his amended claims, and vacate the magistrate judge assignment in the case because he alleges actual innocence. (Id.) Respondent filed an opposition to this motion on April 6, 2022, arguing Respondent did not need leave of court to re-serve courtesy copies of filings that had been previously served.

(ECF Doc. 33.) Respondent also argued that it would not be appropriate or warranted for the Court to take judicial notice of disputed claims or claims that are not sufficiently plead. (Id.) “Amendment of a petition for habeas corpus is governed by the ‘rules of procedure applicable to civil actions.’” Hodges v. Rose, 570 F.2d 643, 649 (6th Cir. 1978) (citing 28 U.S.C. § 2242

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

Related

Landis v. North American Co.
299 U.S. 248 (Supreme Court, 1936)
Houston v. Lack
487 U.S. 266 (Supreme Court, 1988)
Herrera v. Collins
506 U.S. 390 (Supreme Court, 1993)
Bracy v. Gramley
520 U.S. 899 (Supreme Court, 1997)
Theodore Cook v. Jimmy Stegall, Warden
295 F.3d 517 (Sixth Circuit, 2002)
Thomas Clyde Bowling, Jr. v. Phillip Parker, Warden
344 F.3d 487 (Sixth Circuit, 2003)
Willie Williams, Jr. v. Margaret Bagley, Warden
380 F.3d 932 (Sixth Circuit, 2004)
West v. Bell
550 F.3d 542 (Sixth Circuit, 2008)
Gould v. Control Laser Corp.
705 F.2d 1340 (Federal Circuit, 1983)
Wells v. Brown
891 F.2d 591 (Sixth Circuit, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
Coleman v. McConahay, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coleman-v-mcconahay-ohnd-2022.