Dawson-Durgan v. Warden, Warren Correctional Institution

District Court, S.D. Ohio·Decided August 17, 2020·No. 1:19-cv-00382·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

DONALD DAWSON-DURGAN, Case No. 1:19-cv-382 Petitioner, McFarland, J. vs. Bowman, M.J.

WARDEN, WARREN ORDER AND REPORT CORRECTIONAL INSTITUTION, AND RECOMMENDATION Respondent.

On July 28, 2020, the undersigned issued a Report and Recommendation to deny petitioner’s motion to stay this action and respondent’s motion to dismiss. (See Doc. 16). With respect to the motion to stay, petitioner asked the Court to stay the action so that he can exhaust Grounds Six and Seven of the petition. (Doc. 14). In recommending that the motion be denied, the Court noted that petitioner raised the unexhausted claims in his October 2018 post-conviction petition, which was denied by the trial court. (See Doc. 10, Ex. 27). Petitioner sought an appeal in the Ohio Court of Appeals, which remained pending at the time he filed his petition. (See Doc. 10, Ex. 28–32). The Ohio Court of Appeals dismissed the appeal on March 25, 2020.1 In recommending that petitioner’s motion to stay be denied, the Court reasoned that because petitioner failed to appeal to the Ohio Supreme Court and the Ohio Supreme Court’s Rules of Practice do not permit delayed appeals to the state’s highest court from appeals involving post- conviction relief, see Ohio S.Ct. Prac. R. 7.01(4)(c), that petitioner’s claims were no longer unexhausted. (See Doc. 16). Because it appeared that petitioner had no remaining avenues of relief in the Ohio courts the undersigned recommended that the motion to stay (Doc. 14) and the

1 Viewed at www.clerkcourt.org under Case No. C 1900136. This Court may take judicial notice of court records that are available online to members of the public. See Lynch v. Leis, 382 F.3d 642, 648 n.5 (6th Cir. 2004) (citing Lyons v. Stovall, 188 F.3d 327, 332 n.3 (6th Cir. 1999)). motion to dismiss for lack of exhaustion (Doc. 11) be denied. In response to the Report and Recommendation, petitioner has provided an Ohio Supreme Court Entry regarding the tolling of the statute of limitations and time limitations under the Ohio Revised Code due to the COVID-19 pandemic. In addition to tolling applicable limitations periods and time limits, the Entry indicates that “the Court will . . . grant reasonable requests to extend the time for filing of any type of document, provided that the request is necessitated by the COVID-19 emergency. A party may also file a motion for leave to file out of time, and the Clerk shall accept the motion if the delay in filing is due to the effects of or measures necessitated by the COVID-19 emergency.” (See Doc. 17 at PageID 379). Petitioner

argues that he has been locked down due to COVID-19 without access to a computer or the law library, that he intends to file an appeal in the Ohio Supreme Court, and that he has until September 14, 2020 to file a timely appeal. (Id. at PageID 376). An application for a writ of habeas corpus by a state prisoner shall not be granted unless the petitioner has exhausted his state court remedies, there is an absence of available state corrective process, or circumstances exist that render such process ineffective to protect petitioner’s rights. 28 U.S.C. § 2254(b)(1). A state defendant with federal constitutional claims is required to first fairly present those claims to the state courts for consideration because of the equal obligation of the state courts to protect the constitutional rights of criminal defendants and in order to prevent needless friction between the state and federal courts. See Anderson v.

Harless, 459 U.S. 4, 6 (1982) (per curiam); Picard v. Connor, 404 U.S. 270, 275–76 (1971). Under the “fair presentation” requirement, “state prisoners must give the state courts one full opportunity to resolve any constitutional issues by invoking one complete round of the State’s 2 established appellate review process,” which, in Ohio, includes discretionary review in the Ohio Supreme Court. See O’Sullivan v. Boerckel, 526 U.S. 838, 842 (1999); Hafley v. Sowders, 902 F.2d 480, 483 (6th Cir. 1990); Leroy v. Marshall, 757 F.2d 94, 97, 99–100 (6th Cir. 1985). If the petitioner fails to fairly present his claims through the requisite levels of state appellate review, but still has an avenue open to him in the state courts by which he may present the claims, his petition is subject to dismissal without prejudice for failure to exhaust state remedies. See 28 U.S.C. § 2254(c). Although the exhaustion requirement is not jurisdictional, and an application for writ of habeas corpus may be denied on the merits notwithstanding the petitioner’s failure to exhaust state remedies, see 28 U.S.C. § 2254(b)(2), there is a strong

presumption in favor of requiring exhaustion of state remedies. See Granberry v. Greer, 481 U.S. 129, 131 (1987). A “mixed” petition containing both unexhausted claims and claims that have been fairly presented to the state courts is subject to dismissal without prejudice on exhaustion grounds. Rose v. Lundy, 455 U.S. 509, 510, 522 (1982). The 1996 Antiterrorism and Effective Death Penalty Act (AEDPA) “preserve[s] Lundy’s total exhaustion requirement” and “impose[s] a one-year statute of limitations on the filing of federal habeas petitions. Rhines v. Weber, 544 U.S. 269, 275 (2005). Some federal courts (including the Sixth Circuit) have adopted a “stay-and-abeyance” procedure to ensure habeas review is not precluded in the class of cases where a timely-filed federal habeas petition is dismissed on exhaustion grounds and the petitioner subsequently returns to federal court to

present his claims in a renewed petition after exhausting his state remedies only to find that his claims are barred from review by the one-year statute of limitations set forth in 28 U.S.C. §

3 2244(d)(1). See, e.g., Griffin v. Rogers, 308 F.3d 647, 652 & n.1 (6th Cir. 2002); Palmer v. Carlton, 276 F.3d 777, 778–81 (6th Cir. 2002). In Rhines, 544 U.S. at 276, the Supreme Court affirmed that district courts have the discretion to issue stays in habeas cases, but such discretion is circumscribed to the extent it must “be compatible with AEDPA’s purposes.” The Court pointed out that one of AEDPA’s purposes is to “reduce delays in the execution of state and federal criminal sentences” based on the “well- recognized interest in the finality of state judgments.” Id. (quoting Woodford v. Garceau, 538 U.S. 202, 206 (2003), and Duncan v. Walker, 533 U.S. 167, 179 (2001)). In addition, AEDPA’s statute of limitations tolling provision was intended to “reinforce[] the importance of Lundy’s

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Dawson-Durgan v. Warden, Warren Correctional Institution, (S.D. Ohio 2020).

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Related

Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Anderson v. Harless
459 U.S. 4 (Supreme Court, 1982)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Granberry v. Greer
481 U.S. 129 (Supreme Court, 1987)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Woodford v. Garceau
538 U.S. 202 (Supreme Court, 2003)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Willis Leroy v. R.C. Marshall, Supt.
757 F.2d 94 (Sixth Circuit, 1985)
Earl Glen Hafley v. Dewey Sowders, Warden
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Theodore J. Lyons v. Clarice Stovall
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276 F.3d 777 (Sixth Circuit, 2002)
Sandra Maxwell Griffin v. Shirley A. Rogers, Warden
308 F.3d 647 (Sixth Circuit, 2002)
Lynch v. Leis
382 F.3d 642 (Sixth Circuit, 2004)