Evitt v. Harp

CourtDistrict Court, E.D. Oklahoma
DecidedJuly 24, 2023
Docket6:22-cv-00358
StatusUnknown

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

Bluebook
Evitt v. Harp, (E.D. Okla. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

CARINZO JARON EVITT,

Petitioner,

v. Case No. 22-CV-358-JFH-GLJ

STEVEN HARPE,

Respondent.

OPINION AND ORDER Petitioner Carinzo Jaron Evitt, a state prisoner appearing pro se,1 brings this action pursuant to 28 U.S.C. § 2254, seeking federal habeas relief from the judgment entered against him in the District Court of Muskogee County, Case No. CF-2017-357. Dkt. No. 1. Respondent Steven Harpe has moved to dismiss the petition on the basis that Evitt failed to file it within the one-year limitations period prescribed in 28 U.S.C. § 2244(d)(1), and, in the alternative, that Evitt failed to exhaust available state remedies before filing the petition, in contravention of 28 U.S.C. § 2254(b)(1)(A).2 Dkt. No. 6; Dkt. No. 7. Evitt has not submitted a response in opposition to the motion. For the reasons discussed herein, the Court grants Harpe’s motion and dismisses the petition. BACKGROUND On November 27, 2017, Evitt entered a plea of guilty in the District Court of Muskogee

1 Because Evitt appears without counsel, the Court must liberally construe his pleadings. Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). But the rule of liberal construction neither requires nor permits the Court to act as an advocate on his behalf by crafting legal arguments or scouring the record for facts to support his claims. Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836, 840 (10th Cir. 2005). 2 Because the Court finds that Evitt’s petition is untimely, the Court does not reach Harpe’s alternative argument for dismissal. County, Case No. CF-2017-357 to possession of a firearm after a former felony conviction, in violation of Okla. Stat. tit. 21, § 1283. Dkt. No. 7-1, at 1-12.3 The state district court sentenced Evitt to a ten-year term of imprisonment. Dkt. No. 7-2 at 1. Evitt did not move to withdraw his plea within ten (10) days of sentencing, a precondition to seeking direct review of his conviction

and sentence through a certiorari appeal with the Oklahoma Court of Criminal Appeals (OCCA). Dkt. No. 7-3 at 5; see Clayton v. Jones, 700 F.3d 435, 441 (10th Cir. 2012). Over three years later, on April 8, 2021, Evitt filed an application for postconviction relief in the state district court, which the court denied on February 15, 2022. Dkt. No. 7-4; Dkt. No. 7- 5. Evitt appealed to the OCCA, which declined jurisdiction due to the untimeliness of Evitt’s notice of postconviction appeal. Dkt. No. 7-6. Evitt filed a second application for postconviction relief on August 1, 2022, which the state district court denied on August 26, 2022. Dkt. No. 7-7, Dkt. No. 7-8. Evitt appealed the decision to the OCCA, which affirmed the district court’s denial of relief on November 9, 2022. Dkt. No. 7-9. Evitt then initiated this federal habeas action on December 1, 2022, alleging that he

received ineffective assistance of counsel and that, under the dictates of McGirt v. Oklahoma, 140 S. Ct. 2452 (2020), the state court lacked jurisdiction to convict him. Dkt. No. 1 at 5-20, 28-36, 44. DISCUSSION Under the Antiterrorism and Effective Death Penalty Act (AEDPA), state prisoners have one year from the latest of four triggering events in which to file a federal habeas petition. 28 U.S.C. § 2244(d)(1). These events include: (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;

3 The Court’s citations refer to the CM/ECF header pagination. (B) the date on which the impediment to filing an application created by State action in violation of the 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.

28 U.S.C. § 2244(d)(1)(A)-(D). The one-year limitations period generally runs from the date the judgment became “final” under § 2244(d)(1)(A), unless a petitioner alleges facts that implicate § 2244(d)(1)(B), (C), or (D). See Preston v. Gibson, 234 F.3d 1118, 1120 (10th Cir. 2000). A. The Applicable Limitations Period Evitt contends that his petition is timely because he was “[o]nly recently . . . made aware that his conviction is illegal” due to lack of jurisdiction. Dkt. No. 1 at 42-43. Even if the Court liberally construes this argument as invoking § 2244(d)(1)(D), Evitt has not demonstrated that the factual predicate of his claims could not have been discovered prior to the date his conviction became final. Evitt’s jurisdictional claim is predicated on the facts that he is an American Indian and the crime took place in Indian Country. Similarly, his claim of ineffective assistance of counsel is predicated on his counsel’s failure to raise this jurisdictional challenge. The fact that the Creek Reservation has not been disestablished, however, was discoverable through the exercise of due diligence long before the Supreme Court analyzed the issue in its 2020 ruling. See Ford v. Dowling, No. 22-6138, 2023 WL 2641476, at *3 (10th Cir. Mar. 27, 2023) (unpublished) (“[Section] 2244(d)(1)(D) is inapplicable because nothing in McGirt can be said to reveal a new factual predicate for [the petitioner’s] claim.”);4 Stiltner v. Nunn, No. 21-CV-0374-GKF-CDL, 2022 WL 951997, at *5 (N.D. Okla. Mar. 29, 2022) (unpublished) (“[A] reasonably diligent petitioner could have discovered the facts necessary to challenge Oklahoma’s criminal jurisdiction before McGirt was decided in 2020.”). Thus, § 2244(d)(1)(D) does not afford Evitt a later

initiation date of the one-year limitations period. Since Evitt has failed to allege facts triggering 28 U.S.C. § 2244(d)(1)(B), (C), or (D), the one-year limitations period for his petition began to run pursuant to § 2244(d)(1)(A) on the date on which his conviction became final. Evitt appears to argue that, because the state court lacked “jurisdiction over his conviction,” “[t]here [was] no conviction,” for purposes of § 2244(d)(1)(A). Dkt. No. 1, at 43. Yet, claims that a judgment was imposed without proper jurisdiction are not exempt from the AEDPA’s one-year statute of limitations. See Pacheco v. Habti, 62 F.4th 1233, 1245 (10th Cir. 2023) (“When Congress enacted the limitations period in AEDPA, it discerned no reason to provide a blanket exception for jurisdictional claims.”); Murrell v. Crow, 793 F. App’x 675, 679 (10th Cir. 2019) (holding that, “as with any other habeas claim,” the petitioner’s claim

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Bluebook (online)
Evitt v. Harp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/evitt-v-harp-oked-2023.