Donald C. Burrell v. Eric Armel

CourtDistrict Court, M.D. Pennsylvania
DecidedJuly 2, 2026
Docket1:23-cv-00582
StatusUnknown

This text of Donald C. Burrell v. Eric Armel (Donald C. Burrell v. Eric Armel) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Donald C. Burrell v. Eric Armel, (M.D. Pa. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

DONALD C. BURRELL,

Petitioner, CIVIL ACTION NO. 1:23-cv-00582

v. (SAPORITO, J.)

ERIC ARMEL, .,

Respondents.

MEMORANDUM Donald C. Burrell, incarcerated at SCI-Fayette in La Belle, Pennsylvania, commenced this case by filing a petition for writ of pursuant to 28 U.S.C. § 2254. The Court appointed counsel for Burrell, and counsel filed an amended petition on Burrell’s behalf, which is ripe for adjudication. For the following reasons, the petition will be denied. I. STATEMENT OF THE CASE On June 25, 2015, in the Court of Common Pleas of Bradford County, a jury convicted Burrell of more than 300 charges arising from the sexual abuse of his daughter. On appeal, the Pennsylvania Superior Court summarized the facts as follows: In 2013, Burrell was charged with sexually assaulting his daughter consistently over a 20 year period. He had previously been charged with many of the same crimes in 2002, but after his daughter had recanted, the Commonwealth the charges. The charges were filed again in 2013, alongside charges arising from conduct occurring between 2002 and 2013. In pre-trial motions, Burrell raised the issue of his competency to stand trial, whether double jeopardy barred the prosecution of the crimes he had been charged with in 2002, and whether the search warrant for his computer was overbroad. After the trial court denied all three motions, the case proceeded to a jury trial. At trial, the victim testified that Burrell kept a calendar that memorialized the abuse, as well as assorted other evidence. The calendar recorded over 200 incidents of sexual intercourse between Burrell and his daughter. The jury found him guilty on all charges. The trial court subsequently sentenced Burrell to an aggregate sentence of 1,031 to 2,546 years of imprisonment. It accomplished this sentence by running the sentences for all non-merged convictions consecutively. , No. 660 MDA 2016, 2017 WL 2805172, at *1 (Pa. Super. Ct. June 28, 2017). Burrell appealed his convictions, asserting that the trial court erred by: (1) determining that he was competent to stand trial; (2) denying his motion to suppress evidence seized from his computer; (3) allowing evidence of crimes prior to 2003 to be presented at trial; (4) determining that the evidence at trial was sufficient to support his convictions; and (5) imposing an excessive sentence. The Pennsylvania Superior Court affirmed on June 28, 2017. Burrell

filed a Petition for Allowance of Appeal, which was denied on December 27, 2017. , 644 Pa. 518 (2017). It is undisputed that Burrell did not seek in the United States Supreme Court.

Burrell filed a Post-Conviction Relief Act (“PCRA”) petition, which the state court received on December 7, 2018. Through appointed counsel, Burrell filed an amended petition on February 18, 2021,

asserting ineffective assistance by trial counsel on six different grounds. (Doc. 23-8). The court denied relief on September 15, 2021. (Doc. 23- 9). Burrell appealed, and the Superior Court affirmed on January 19,

2023. , 292 A.3d 1110 (Pa. Super. Ct. 2023). Burrell did not file a Petition for Allowance of Appeal. Burrell filed his habeas petition1 pursuant to 28 U.S.C. § 2254,

1 Contrary to the respondent’s argument, this petition was timely filed. In general, a one-year period of limitation applies to Section 2254 petitions. That period began on “the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review.” 28 U.S.C. § 2244(d)(1). For Burrell, that date was March 27, 2018, at the conclusion of the 90-day period for him to seek in the United States Supreme Court. , 204 F.3d 417, 419 (3d Cir. 2000); 42 Pa.C.S. § 9545(b)(3) (“a judgment becomes final at the conclusion of direct review, including discretionary review in the Supreme Court of the United States”). dated March 24, 2023, in the Eastern District of Pennsylvania. The court

transferred the petition to this district because Burrell was convicted in Bradford County, within the boundaries of this district. (Doc. 4). On July 1, 2025, upon review of the petition and response, the Court

appointed counsel to represent Burrell (Doc. 34), and counsel filed an amended petition on October 6, 2025 (Doc. 43). A. Habeas Claims Presented In the operative petition (Doc. 43), Burrell asserts four grounds for

relief: • (1) The state courts “erred by not addressing Mr. Burrell’s argument concerning the effect of the of the 2002 and 2003 charges on the Commonwealth’s ability to bring the same charges in the 2014 case.”

From that date, 234 days passed until Burrell filed his PCRA petition, which tolled the one-year limitation period. 28 U.S.C. § 2244(d)(2). Although his petition was file-stamped December 7, 2018, the petition is dated November 16, 2018, Burrell claims he submitted it for mailing on that date, and the respondent offers no evidence to the contrary. , 435 F. Supp. 2d 410, 419 (E.D. Pa. 2006) (the prison mailbox rule applies to PCRA petitions) (citing , 549 Pa. 58 (1997)). The Superior Court affirmed denial of Burrell’s PCRA petition on January 19, 2023. The limitation period did not resume until 30 days later, when the deadline to file a Petition for Allowance of Appeal had passed. , 204 F.3d at 420-25. A further 34 days elapsed until March 24, 2023, when this habeas petition was dated and mailed. (Doc. 1 at 22). Ultimately, accounting for tolling, 268 days elapsed after Burrell’s judgment became final, and thus his petition was timely filed. • (2) Trial counsel was ineffective for failing to challenge a May 25, 2013, search warrant, pursuant to which Burrell’s laptop was seized; alternatively, if the warrant had not been produced to trial counsel, the prosecution violated Burrell’s rights pursuant to , 373 U.S. 83 (1963).

• (3) The evidence at trial was insufficient to sustain Burrell’s convictions.

• (4) Burrell’s sentence of 1,031 to 2,531 years violated the Eighth Amendment and his due process rights.

II. LEGAL STANDARDS A federal court may not grant relief on habeas claims previously adjudicated on the merits in state court unless that adjudication: (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State Court proceeding. 28 U.S.C. § 2254(d). In drafting this statute, Congress “plainly sought to ensure a level of ‘deference to the determinations of state courts,’ provided those determinations did not conflict with federal law or apply federal law in an unreasonable way.” , 529 U.S. 362, 386 (2000); , 712 F.3d 837, 846 (3d. Cir. 2013). Consequently, “state-court judgments must be upheld unless, after the

closest examination of the state-court judgment, a federal court is firmly convinced that a federal constitutional right has been violated.” , 529 U.S. at 387.

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Donald C. Burrell v. Eric Armel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/donald-c-burrell-v-eric-armel-pamd-2026.