Duncan v. Wright (INMATE 3)

CourtDistrict Court, M.D. Alabama
DecidedJune 10, 2021
Docket1:18-cv-00670
StatusUnknown

This text of Duncan v. Wright (INMATE 3) (Duncan v. Wright (INMATE 3)) 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
Duncan v. Wright (INMATE 3), (M.D. Ala. 2021).

Opinion

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

SHARON D. DUNCAN, #148434, ) ) Petitioner, ) ) v. ) Case No. 1:18-cv-670-ECM-SMD ) [WO] DEIDRA WRIGHT and STEVEN T. MARSHALL, ) ) Respondents. )

RECOMMENDATION OF THE MAGISTRATE JUDGE Before the court is a petition for writ of habeas corpus under 28 U.S.C. § 2254 filed on June 25, 2018, by Sharon D. Duncan, an Alabama inmate proceeding pro se. Doc. 1. Duncan challenges her Houston County convictions for receiving stolen property, theft of property, and criminal possession of a forged instrument. For the following reasons, the undersigned Magistrate Judge RECOMMENDS that Duncan’s petition be DENIED without an evidentiary hearing and that this case be DISMISSED with prejudice. I. BACKGROUND A. State Criminal Conviction On October 21, 1998, Duncan was convicted in the Houston County Circuit Court following guilty pleas to one count of first-degree receiving stolen property, two counts of second-degree theft of property, and seven counts of criminal possession of a forged instrument. See Doc. 15-1. For each conviction, Duncan was sentenced to a term of life in prison under Alabama’s Habitual Felony Offender Act, with all terms ordered to run concurrently. Id. Duncan did not appeal. B. Alabama Rule 32 Petition

In June 2000, Duncan filed a petition in the state trial court seeking post-conviction relief under Rule 32 of the Alabama Rules of Criminal Procedure. Doc. 15-1. Duncan’s Rule 32 petition raised claims that her guilty plea was involuntary and that she received ineffective assistance of trial counsel. Id. The trial court denied Duncan’s Rule 32 petition in August 2000, and Duncan appealed. On February 16, 2001, the Alabama Court of

Criminal Appeals issued a memorandum opinion affirming the trial court’s judgment denying Duncan’s Rule 32 petition. Id. On April 6, 2001, the Court of Criminal Appeals issued on a certificate of judgment. Doc. 15-2. C. 2008 Sentence Reduction On May 27, 2008, Duncan filed a motion with the trial court seeking a sentence

reduction under Kirby v. State, 899 So.2d 968 (Ala. 2004) and ALA. CODE § 13A-5-9.1. Doc. 15-3. On July 3, 2008, the trial court granted Duncan’s motion for sentence reduction and entered an order reducing the sentence for her receiving-stolen-property conviction to 20 years in prison, to run concurrently with her other sentences. Doc. 15-3. Under the trial court’s order, Duncan’s life sentences for her other Houston County convictions remained

the same. Id. Duncan did not appeal the resentencing. D. May 2009 Federal Habeas Petition Duncan filed a 28 U.S.C. § 2254 petition with this court on May 6, 2009. See Duncan v. Wheeler-White, 1:09-CV-416-TMH-SRW. The petition was dismissed without prejudice on September 22, 2019, to allow Duncan to pursue her available state court remedies regarding claims in the petition. Id. E. The Instant Federal Habeas Petition

Duncan filed this § 2254 petition on June 25, 2018.1 Doc. 1. In her petition, Duncan contends that she received ineffective assistance of counsel, that she was misinformed about the length of the sentences she would receive, that she was not afforded on opportunity for drug treatment before sentencing, and that her life sentences should all be reduced. Id at 5–10. Respondents answer that Duncan’s petition is time-barred under the

one-year federal limitation period. Doc. 15 at 4–6. II. DISCUSSION A. AEDPA’s Statute of Limitations The Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”) includes a one-year statute of limitations for filing a § 2254 petition. Title 28 U.S.C. § 2244(d) of

AEDPA states: (1) 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. The limitation period shall run from the latest of—

(A) the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review;

(B) the date on which the impediment to filing an application created by State action in violation of the

1 Duncan’s § 2254 petition was stamped as received in this court on July 17, 2018. Doc. 1 at 1. Applying the “prison mailbox rule,” the court deems Duncan’s petition to be filed on the date she represents that she delivered it to prison authorities for mailing, i.e., June 25, 2018. Id. at 15. See Jeffries v. United States, 748 F.3d 1310, 1314 (11th Cir. 2014). Constitution or laws of the United States is removed, if the applicant was prevented from filing by such State action;

(C) the date on which the constitutional right asserted was initially recognized by the Supreme Court, if the right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review; or

(D) the date on which the factual predicate of the claim or claims presented could have been discovered through the exercise of due diligence.

(2) The time during which a properly filed application for State post- conviction or other collateral review with respect to the pertinent judgment or claim is pending shall not be counted toward any period of limitation under this subsection.

28 U.S.C. § 2244(d). B. Analysis of Timeliness For purposes of AEDPA’s statute of limitations, the court will assume that the judgment that holds Duncan in confinement is the state trial court’s July 3, 2008 order granting Duncan’s motion for sentence reduction and reducing the sentence for her receiving-stolen-property conviction to 20 years in prison, even though that order left all of Duncan’s convictions intact and left unchanged the life sentences for her other convictions. Thompson v. Fla. Dep’t of Corr., 606 F. App’x 495, 505 (11th Cir. 2015); see Magwood v. Patterson, 561 U.S. 320, 341–42 (2010); Insignares v. Sec’y, Fla. Dep’t of Corr., 755 F.3d 1273, 1281 (11th Cir. 2014). Duncan had 42 days to appeal the trial court’s July 3, 2008 judgment. See ALA. R. APP. P. 4(b)(1). However, she did not appeal. Therefore, for purposes of AEDPA’s statute of limitations, that judgment became final on August 14, 2008, when the time for Duncan to appeal the judgment expired. Under 28 U.S.C. § 2244(d)(1)(A), AEDPA’s one-year limitation period runs from the date on which a petitioner’s state court judgment becomes final, either “by the conclusion of direct review or the expiration of the time for seeking such review.” Pugh v. Smith, 465 F.3d 1295, 1298

(11th Cir. 2006) (quoting § 2244(d)(1)). Absent statutory or equitable tolling, then, Duncan had until August 14, 2009, to file her § 2254 petition. 1. Statutory Tolling Under 28 U.S.C. § 2244(d)(2), the one-year limitation period is tolled while a properly filed state post-conviction petition is pending in the state courts. Duncan,

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Bluebook (online)
Duncan v. Wright (INMATE 3), Counsel Stack Legal Research, https://law.counselstack.com/opinion/duncan-v-wright-inmate-3-almd-2021.