Cook v. Garrett

CourtDistrict Court, D. Nevada
DecidedMarch 10, 2022
Docket3:19-cv-00081
StatusUnknown

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

Bluebook
Cook v. Garrett, (D. Nev. 2022).

Opinion

3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 * * *

6 BRIAN CLAY COOK, Case No. 3:19-cv-00081-MMD-CLB

7 Petitioner, ORDER v. 8 RENEE BAKER, et al., 9 Respondents. 10 11 I. SUMMARY 12 This is a habeas corpus action under 28 U.S.C. § 2254 filed by Brian Cook. The 13 third amended petition is the operative petition. (ECF No. 49.) Currently before the Court 14 are Respondents’ motion to dismiss and Cook’s opposition. (ECF Nos. 64, 81.) 15 Respondents filed a reply, but it was for a different action. (ECF No. 90.) The Court will 16 strike the reply to avoid confusion in the future. This action was untimely commenced, but 17 the Court finds that equitable tolling is warranted. The Court disagrees with most of 18 Respondents’ other arguments, deferring a determination of prejudice to excuse the 19 procedural default of ground 7 until the Court reaches the merits of the petition. The Court 20 thus denies the motion to dismiss in part. 21 II. BACKGROUND 22 On January 14, 2014, after a jury trial, Cook was convicted of three counts of sexual 23 assault with a minor under the age of 14, two counts of sexual assault with a minor under 24 the age of 16, two counts of sexual assault, and one count of battery with intent to commit 25 sexual assault. (ECF No. 71-3.) Cook appealed. The Nevada Supreme Court affirmed on 26 October 14, 2016. (ECF No. 73-13.) Cook filed a petition for rehearing, and the Nevada 27 Supreme Court denied it. (ECF Nos. 73-14, 73-15.) Cook filed a petition for 28 2 (ECF Nos. 73-16, 73-17.) Remittitur issued on March 21, 2017. (ECF No. 73-18.) 3 On April 3, 2017, Cook filed a proper-person motion for order of delivery of records. 4 (ECF No. 73-20.) He asked the state district court to order trial counsel to give his case 5 file to him. (Id.) Cook wrote in an affidavit at the end: 6 Mike Felliciano [one of Cook's public-defender attorneys] ignores my letters and refuses to answer any attempts to contact him at all, much like he did in 7 my trial where I was falsely accused, pathetically tried and wrongfully convicted and illegally incarcerated due to his [incompetence] and complete 8 [disregard] for actual justice or truth, human dignity. Mr. Felliciano is ignoring me. 9 10 (ECF No. 73-20 at 5.) Cook was not present at the hearing on this motion on April 24, 11 2017. There, Amy Coffee, Cook's other public-defender attorney, asked the court to 12 appoint counsel for Cook to file motions with the aid of an attorney. She noted that Cook 13 had had multiple health issues, but that she did not know the current state of his health. 14 The prosecutor asked to be allowed to respond to that motion for appointment of counsel. 15 The state district court noted the prosecutor’s request and appointed post-conviction 16 counsel before Cook had filed a post-conviction habeas corpus petition. (ECF No. 65-1 at 17 38 (court minutes).) This is where the problem started. 18 On May 10, 2017, Karen Connolly confirmed that she would represent Cook, and 19 the court set a status check for June 21, 2017. (ECF No. 65-1 at 41 (court minutes).) On 20 June 21, 2017, Connolly stated that she had received the file, and she requested a 6- 21 month deadline to file the writ. The state district court set December 20, 2017, as the due 22 date to file a supplement to the petition. (ECF No. 65-1 at 42.) 23 Two provisions of Nevada law are relevant to this problem. First, if a person 24 convicted in a Nevada Court has appealed the judgment of conviction and wishes to file a 25 post-conviction habeas corpus petition, then that petition is due no later than one year 26 after the Nevada Supreme Court issues its remittitur from the direct appeal. See NRS 27 § 34.726(1). Second, if, after reviewing an indigent proper-person petition the state district 28 court determines that representation by counsel is necessary, then the state district court 2 § 34.750(1), (3). 3 The state district court skipped over an important step. Cook had not filed a post- 4 conviction petition before the state district court appointed Connolly and set a due date for 5 a supplement to the petition. However, the due date of December 21, 2017, was well within 6 Nevada’s one-year period to file a petition. 7 On December 21, 2017, Connolly (on Cook’s behalf) filed a Motion Requesting 8 Additional Time to File the Supplement to the Petition for Writ of Habeas Corpus. (ECF 9 No. 73-23 (emphasis added).) Connolly stated that she “needs additional time to complete 10 the investigation and to prepare the supplement to the petition.” (Id. at 3 (emphasis 11 added).) Part of the text following that statement is missing; this is a problem with the 12 original document, not the filing of the exhibit, because the internal pagination is 13 consistent. From what is available, a deputy district attorney identified only as “he” did not 14 object to the additional time and initially was willing to sign a stipulation. This deputy district 15 attorney might have been Steven Owens, because the other deputy district attorney 16 involved with the case was a woman. Later, Owens told Connolly that she would need to 17 file a motion instead. (Id. at 4.) On January 3, 2018, the state district court granted the 18 motion, with a briefing schedule to be set later. (ECF No. 65-1 at 43 (court minutes).) On 19 March 21, 2018, Nevada’s one-year period to file a post-conviction habeas corpus petition 20 expired. See NRS § 34.726(1). On May 25, 2018, the federal one-year period to file a 21 habeas corpus petition expired, as the Court will discuss below. See 28 U.S.C. 22 § 2244(d)(1)(A). On June 4, 2018, an attorney standing in for Connolly stated that the 23 parties had agreed on September 7, 2018, as the due date for filing the petition. (ECF No. 24 65-1 at 45 (court minutes).) Both the date of the hearing and the due date for filing the 25 state petition were after the expiration of both the state and the federal one-year periods 26 of limitation. 27 On September 11, 2018, Cook filed a post-conviction habeas corpus petition in the 28 criminal action. (ECF No. 73-24.) In the procedural history part of the petition, Cook stated, 2 requested additional time to file the writ. The State did not oppose those requests. An 3 extension was granted until September 7, 2018.” (Id. at 3-4). Cook later filed a supplement 4 to the petition, but that only explained that he had initially filed the petition in the wrong 5 action. (ECF No. 73-28.)1 6 Chief Deputy District Attorney Steven Owens authored the response to the petition. 7 In relevant part, respondents argued that the petition was time-barred under NRS 8 § 34.726(1) because Cook filed the petition almost six months after the one-year period 9 had expired on March 21, 2018. (ECF No. 73-29 at 5-6.) Respondents also argued that 10 Cook had not shown good cause and prejudice to overcome the time bar. (ECF No. 73- 11 29 at 6-14.) Cook replied that respondents were not arguing in good faith because they 12 had agreed to the initial request to extend the due date for the petition and then agreed 13 upon the due date. (ECF No. 73-30 at 3.) 14 The state district court held a hearing over two days. (ECF Nos. 74-1, 74-2.) At the 15 end of the hearing on January 9, 2019, the state district court denied the petition as 16 untimely. (ECF No.

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

Related

Holmberg v. Armbrecht
327 U.S. 392 (Supreme Court, 1946)
Glus v. Brooklyn Eastern District Terminal
359 U.S. 231 (Supreme Court, 1959)
United States v. Frady
456 U.S. 152 (Supreme Court, 1982)
Anderson v. Harless
459 U.S. 4 (Supreme Court, 1982)
Vasquez v. Hillery
474 U.S. 254 (Supreme Court, 1986)
Murray v. Carrier
477 U.S. 478 (Supreme Court, 1986)
Irwin v. Department of Veterans Affairs
498 U.S. 89 (Supreme Court, 1991)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Jimenez v. Quarterman
555 U.S. 113 (Supreme Court, 2009)
Maples v. Thomas
132 S. Ct. 912 (Supreme Court, 2012)
Duncan v. Henry
513 U.S. 364 (Supreme Court, 1995)
State v. Haberstroh
69 P.3d 676 (Nevada Supreme Court, 2003)
Hess v. State
20 P.3d 1121 (Alaska Supreme Court, 2001)
Anthony Smith v. Ron Davis
953 F.3d 582 (Ninth Circuit, 2020)
State v. Eighth Judicial District Court
112 P.3d 1070 (Nevada Supreme Court, 2005)
Watters v. State
313 P.3d 243 (Nevada Supreme Court, 2013)
Rudin v. Myles
781 F.3d 1043 (Ninth Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Cook v. Garrett, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cook-v-garrett-nvd-2022.