Howard v. Babers (INMATE 1)

CourtDistrict Court, M.D. Alabama
DecidedJune 15, 2023
Docket2:22-cv-00640
StatusUnknown

This text of Howard v. Babers (INMATE 1) (Howard v. Babers (INMATE 1)) 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
Howard v. Babers (INMATE 1), (M.D. Ala. 2023).

Opinion

IN THE UNITED STATE DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

DARON DWANE HOWARD, ) #159809, ) ) Petitioner, ) ) v. ) CASE NO. 2:22-cv-640-ECM-JTA ) GWENDOLYN BABERS, et al., ) ) Respondents. )

RECOMMENDATION OF THE MAGISTRATE JUDGE Alabama inmate Daron Dwane Howard filed a pro se Petition for Writ of Habeas Corpus under 28 U.S.C. § 2254 in which he challenges his revocation of probation following his convictions for possession of a forged instrument, possession of a controlled substance, and theft of property. (Doc. No. 1.) For the reasons discussed below, the undersigned RECOMMENDS that Howard’s Petition be DENIED as time-barred under the federal statute of limitations. See 28 U.S.C. § 2244(d)(1)(A). I. BACKGROUND A. Howard’s State Court Proceedings In or around November 2019, Howard was placed on probation following his convictions for possession of a forged instrument in the third degree, possession of a controlled substance, and theft of property in the first degree. (Doc. No. 15-1 at 5.) Howard did not directly appeal his convictions and sentences. On January 17, 2020, Howard’s probation officer filed a delinquency report alleging that Howard violated the terms and conditions of his probation by failing to report. (Id. at

5–6, 8–9, 63–64, 66–67, 119–120.) On March 13, 2020, Howard’s probation officer filed a second delinquency report alleging that Howard violated the terms and conditions of his probation based on his arrest for a new criminal charge of assault in the second degree. (Id. at 38.) After Howard’s probation revocation hearing, at which Howard was present and represented by counsel, the circuit court entered an order finding that Howard violated the conditions of his probation by failing to report to his probation officer and committing a

new criminal offense of assault in the second degree. (Id. at 25–26, 50–51, 83–84, 108– 109, 139–140, 162–163.) Howard did not file any post judgment motions. Howard appealed the circuit court’s ruling in the Alabama Court of Criminal Appeals and argued that the State failed to present “sufficient corroborative evidence to sustain a revocation of probation.” (Doc. No. 15-2 at 9.) Specifically, Howard argued that

the State failed to produce testimony from a witness to the assault; failed to provide any photographs of the injury from the assault; and failed to offer any medical reports regarding the injury. (Id. at 9–10; Doc. No. 15-3 at 3.) Additionally, he argued that he was not served with written notice of the alleged probation violations in violation of his due process rights. (Doc. No. 15-2 at 11; Doc. No. 15-3 at 5.)

In a Memorandum Decision issued on December 11, 2020, the Court of Criminal Appeals held that the State provided sufficient evidence to support the circuit court’s revocation of Howard’s probation based on Howard committing a new criminal offense of assault in the second degree. (Doc. No. 15-3 at 4.) Regarding his second claim, the Court held that the issue was not preserved for appellate review because Howard did not first raise that issue before the circuit court. (Id. at 5.) Thus, the Court of Criminal Appeals

affirmed the circuit court’s ruling. (Id.) Howard did not file an application for rehearing, and he did not file a petition for a writ of certiorari with the Alabama Supreme Court. The Court of Criminal Appeals issued a Certificate of Judgment on December 30, 2020. (Doc. No. 15-4.) B. Howard’s § 2254 Petition Howard filed this Petition for Writ of Habeas Corpus on October 31, 2022. (Doc.

No. 1 at 15.) In his Petition, he claims that (1) at his probation revocation hearing, the State failed to produce testimony from a witness to the assault as well as photographic evidence; (2) he was not served with written notice of his alleged probation violations; (3) the circuit court did not conduct a probation revocation hearing in accordance with the law; and (4) the circuit court’s order revoking his probation was unlawful. (Id. at 5–11.)

II. DISCUSSION In their Answer, Respondents argue that Howard’s Petition is time-barred pursuant to the applicable statute of limitations.1 (Doc. No. 15 at 3–5.) For the reasons set forth below, the undersigned agrees. The Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”) contains

the following time limitations for federal habeas petitions:

1 Respondents further argue that Howard’s claims are (1) unexhausted and procedurally defaulted because they were not subjected to a complete round of appellate review in the Alabama courts; and (2) meritless. (Doc. No. 15 at 5–9.) However, because the undersigned finds that the Petition is time-barred, the Court pretermits discussion of Howard’s procedural default as well as the merits of his Petition. (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 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). A. Computation of Timeliness of § 2254 Petition In most cases, a § 2254 petition must be filed within one year of the date on which the state court’s judgment becomes final, either by the conclusion of direct review or the expiration of time for seeking direct review. See 28 U.S.C. § 2244(d)(1)(A); Pugh v. Smith, 465 F.3d 1295, 1298 (11th Cir. 2006). In this case, the Alabama Court of Criminal Appeals affirmed the circuit court’s ruling on direct appeal in a Memorandum Decision issued on December 11, 2020. (Doc. No. 15-3.) Howard did not apply for rehearing or seek certiorari review in the Alabama Supreme Court. The Court of Criminal Appeals issued its Certificate of Judgment in the direct review proceedings on December 30, 2020. (Doc. No.

15-4.) Thus, for purposes of § 2244(d)(1)(A), Howard’s judgment became final on December 30, 2020. See Brown v. Hooks, 176 F. App’x 949, 951 (11th Cir. 2006). On that date, the AEDPA’s one-year statute of limitations began to run. Accordingly, absent a statutory or equitable tolling event, Howard had until December 30, 2021 to file a timely § 2254 petition; however, Howard did not file his Petition until October 31, 2022—more than ten months later.

B. Statutory Tolling Pursuant to 28 U.S.C. § 2244

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

Related

Derrick Lakeith Brown v. Ralph Hooks
176 F. App'x 949 (Eleventh Circuit, 2006)
Sandvik v. United States
177 F.3d 1269 (Eleventh Circuit, 1999)
Gerard Joseph Pugh v. Hugh Smith
465 F.3d 1295 (Eleventh Circuit, 2006)
Hunter v. Ferrell
587 F.3d 1304 (Eleventh Circuit, 2009)
Larry Bonner v. City of Prichard, Alabama
661 F.2d 1206 (Eleventh Circuit, 1981)
Murray Stein v. Reynolds Securities, Inc.
667 F.2d 33 (Eleventh Circuit, 1982)
Holland v. Florida
177 L. Ed. 2d 130 (Supreme Court, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
Howard v. Babers (INMATE 1), Counsel Stack Legal Research, https://law.counselstack.com/opinion/howard-v-babers-inmate-1-almd-2023.