Jerry Gilligan v. State of Arizona, et al.

CourtDistrict Court, D. Arizona
DecidedFebruary 2, 2026
Docket3:24-cv-08158
StatusUnknown

This text of Jerry Gilligan v. State of Arizona, et al. (Jerry Gilligan v. State of Arizona, et al.) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jerry Gilligan v. State of Arizona, et al., (D. Ariz. 2026).

Opinion

1 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Jerry Gilligan, No. CV-24-08158-PCT-ROS

10 Petitioner, ORDER

11 v.

12 State of Arizona, et al.,

13 Respondents. 14 15 On November 7, 2024, Petitioner Jerry Gilligan filed a pro se Petition Under 28 16 U.S.C. § 2254 for a Writ of Habeas Corpus. (Doc. 7.) On May 21, 2025, Magistrate Judge 17 John Z. Boyle filed a Report and Recommendation (“R&R) recommending the Petition be 18 denied and dismissed with prejudice and without a Certificate of Appealability. (Doc. 71.) 19 On May 27, 2025, within the fourteen-day period for filing objections to the R&R, 20 Petitioner filed a Motion for Lost or Destroyed Evidence, (Doc. 77), Motion for 21 Reconsideration, (Doc. 78), and Notice of Error, (Doc. 79). On June 10, 2025, Respondents 22 filed a Response to the Motions and Notice to the extent the Court construes the filings as 23 objections to the R&R. (Doc. 80.) 24 Also before the Court are nineteen other motions filed by Petitioner after the time 25 for filing objections expired. As set forth below, the Court will deny Petitioner’s motions, 26 overrule his objections, adopt the R&R in full, and deny and dismiss the Petition with 27 prejudice and without a Certificate of Appealability. 28 1 I. BACKGROUND 2 Magistrate Judge Boyle recounted the factual and procedural background of 3 Petitioner’s appeals and post-conviction relief proceedings in state court. (Doc. 13 at 2–13). 4 As neither party objects to this portion of the R&R, the Court hereby accepts and adopts it. 5 See Thomas v. Arn, 474 U.S. 140, 152 (1989) (“There is no indication that Congress . . . 6 intended [the Federal Magistrates Act, 28 U.S.C. § 636(b)(1)(C)] to require a district judge 7 to review a magistrate’s report to which no objections are filed.”); see also Fed. R. Civ. P. 8 72(b)(3) (“The district judge must determine de novo any part of the magistrate judge’s 9 disposition that has been properly objected to.”). 10 II. LEGAL STANDARD 11 A district judge “may accept, reject, or modify, in whole or in part, the findings or 12 recommendations made by the magistrate judge.” 28 U.S.C. § 636(b). The district court 13 must review de novo the portions to which an objection is made. Id. But the district court 14 need not review the portions to which no objection is made, see Schmidt v. Johnstone, 263 15 F.Supp.2d 1219, 1226 (D. Ariz. 2003), or where an objection merely repeats arguments 16 raised in the habeas petition, see Scott v. Shinn, No. CV-20-02343-PHX-DWL, 2021 WL 17 5833270, at *4 (D. Ariz. Dec. 9, 2021) (“Petitioner’s objections largely amount to his 18 repeating the same arguments he raised in his habeas petition and reply. . . . This approach 19 is impermissible—at this stage of the proceedings, Petitioner must identify specific flaws 20 in the R&R’s reasoning, not simply repeat his earlier arguments.”). Further, “[i]ssues raised 21 for the first time in objections to the magistrate judge’s recommendation are deemed 22 waived.” Williams v. Ryan, No. CV-18-00349-TUC-RM, 2019 WL 4750235, at *5 (D. 23 Ariz. Sept. 30, 2019). 24 Petitions for Habeas Corpus are governed by the Antiterrorism and Effective Death 25 Penalty Act of 1996 (“AEDPA”). 28 U.S.C. § 2244. The AEDPA imposes a one-year 26 limitation period, which begins to run “from the latest of . . . the date on which the judgment 27 became final by the conclusion of direct review or the expiration of the time for seeking 28 such review” or “the date on which the factual predicate of the claim or claims presented 1 could have been discovered through the exercise of due diligence.” 28 U.S.C. 2 § 2244(d)(1).1 3 III. ANALYSIS 4 The R&R recommends the Petition be denied and dismissed with prejudice because 5 the Petition was filed forty-three days after the one-year limitations period expired and 6 Petitioner is not entitled to statutory or equitable tolling, nor has he demonstrated a credible 7 claim of actual innocence to excuse his untimeliness. 8 A. Equitable Tolling 9 The Court construes Petitioner’s Motion for Reconsideration, (Doc. 78), as 10 objecting to the R&R’s conclusion that “Petitioner fails to demonstrate extraordinary 11 circumstances” to equitably toll AEDPA’s one-year filing deadline, (Doc. 71 at 6.) 12 However, Petitioner’s objection merely reasserts the same facts and arguments previously 13 rejected in the R&R. (See id. at 6–7.) As such, the Court need not review this portion of 14 the R&R de novo. See Scott, 2021 WL 5833270, at *4. Noting no clear error in the 15 magistrate judge’s factual or legal conclusions,2 the Court hereby overrules Petitioner’s 16 objection and adopts and accepts this portion of the R&R finding Petitioner is not entitled 17 to equitable tolling. 18 B. Actual Innocence 19 The Court construes Petitioner’s Motion for Lost or Destroyed Evidence (Doc. 77) 20 as objecting to the R&R’s conclusion that Petitioner has not presented new reliable 21 evidence to raise a convincing claim of actual innocence and excuse his untimeliness. 22 Petitioner recites case law to suggest he was entitled to a Willits instruction based on lost 23 or destroyed evidence, but he fails to note what specific evidence he claims was lost or 24 destroyed. Liberally construed,3 the Court interprets Plaintiff’s argument to be the same 25 1 The other two possible dates from which the limitation period may run are not relevant 26 here. See 28 U.S.C. § 2244(d)(1)(B)–(C). 2 Some Ninth Circuit authority suggests a district court must review determinations of law 27 de novo even where no objection is made. See, e.g., Robbins v. Carey, 481 F.3d 1143, 1147 (9th Cir. 2007). 28 3 If construed narrowly as a new argument that Petitioner was entitled to a certain jury instruction, this argument has been waived. 1 one he raised in his prior Motion to Produce Jail House Informant’s Testimony. (See Doc. 2 61.) 3 In the R&R, the magistrate judge denied Petitioner’s Motion to Produce Jail House 4 Informant’s Testimony because his “request for additional discovery in the case bears no 5 relation to the question of whether the Petition is timely.” (Doc. 71 at 10.) To the extent 6 Petitioner now argues this evidence would have established a credible claim of actual 7 innocence and “show that it is more likely than not that no reasonable juror would have 8 convicted him in the light of the new evidence,” see Schlup v. Delo, 513 U.S. 298, 327 9 (1995), the Court disagrees. The Arizona Court of Appeals found there was “overwhelming 10 direct evidence against [Petitioner] presented to the jury, including video evidence.” (Doc. 11 51-1, Ex. G, at 153.) At trial, Petitioner was prepared to present photographs of his genitals 12 showing tattoos and piercings to impeach the victim’s testimony that the victim had not 13 seen any tattoos or piercing on Petitioner’s genitals. (Doc.

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Related

Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
Arthur Robbins, III v. Tom L. Carey
481 F.3d 1143 (Ninth Circuit, 2007)
Austin v. Hopper
15 F. Supp. 2d 1210 (M.D. Alabama, 1998)

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Jerry Gilligan v. State of Arizona, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jerry-gilligan-v-state-of-arizona-et-al-azd-2026.