Joseph W. Bullard v. Secretary, Department of Corrections

CourtDistrict Court, M.D. Florida
DecidedJanuary 12, 2026
Docket8:23-cv-01776
StatusUnknown

This text of Joseph W. Bullard v. Secretary, Department of Corrections (Joseph W. Bullard v. Secretary, Department of Corrections) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph W. Bullard v. Secretary, Department of Corrections, (M.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

JOSEPH W. BULLARD,

Petitioner,

v. Case No. 8:23-cv-1776-MSS-CPT

SECRETARY, DEPARTMENT OF CORRECTIONS,

Respondent. _____________________________________/

O R D E R

Bullard filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254 challenging his state court convictions for one count of possession of child pornography with the intent to promote and fifty counts of possession of child pornography. (Doc. 1) The Respondent asserts that the petition is an unauthorized second or successive petition and untimely. (Doc. 8) After reviewing the petition, the response, the reply (Doc. 10), and the relevant state court record (Doc. 9), the Court DISMISSES in part and DENIES in part Bullard’s petition. PROCEDURAL HISTORY A jury found Bullard guilty of the one count of possession of child pornography with intent to promote and fifty counts of possession of child pornography. (Doc. 9-2 at 80–114) The trial judge sentenced Bullard to an aggregate sentence of sixty years in prison. (Doc. 9-2 at 121–75) Bullard appealed, and the state appellate court affirmed. (Doc. 9-2 at 285) The post-conviction court granted Bullard’s motion to correct an illegal

sentence because the written sentence did not accurately reflect the oral pronouncement. (Doc. 8-2 at 293–95) On February 6, 2013, the trial judge entered an amended judgment, nunc pro tunc to August 9, 2010, the date of the original judgment. (Doc. 9-2 at 297–53) On September 23, 2016, this Court dismissed as untimely Bullard’s petition for

a writ of habeas corpus under 28 U.S.C. § 2254. Bullard v. Sec’y, Dep’t Corrs., No. 8:13- cv-2375-MSS-TBM (M.D. Fla.), ECF No. 23. Bullard did not appeal. In 2020, the post-conviction court granted in part Bullard’s motion to correct an illegal sentence. (Doc. 9-3 at 346–51) Bullard was convicted of fifty-one second-degree

felonies. (Doc. 9-2 at 297–98) The trial judge had sentenced Bullard to 180 months, or fifteen years, in prison for each conviction and ran some convictions consecutively to impose the aggregate sixty-year prison sentence. (Doc. 9-2 at 299–352) Bullard’s lowest permissible sentence for each conviction was 671.85 months, or almost fifty-six years, in prison. (Doc. 9-3 at 347–48) Paradoxically, Bullard complained that the trial

judge should have imposed a sentence of fifty-six years in prison for each conviction, instead of a sentence of fifteen years in prison. (Doc. 9-3 at 307) The post-conviction court agreed and determined that Bullard’s fifteen-year prison sentences for each conviction were illegal. (Doc. 9-3 at 347–50) After considering new evidence at a sentencing hearing, the trial judge reduced Bullard’s sentence to twenty years in prison followed by thirty years of probation. (Doc. 9-3 at 368–69) The trial judge departed downward to reach the new aggregate

twenty-year prison sentence. (Doc. 9-3 at 374–76) On August 12, 2021, the trial judge entered the second amended judgment, nunc pro tunc to August 9, 2010, the date of the original judgment. (Doc. 9-3 at 378–84) On May 11, 2022, the court of appeals denied Bullard’s application for leave to file a second or successive petition under 28 U.S.C. § 2244(b). In re: Joseph Bullard,

No. 22-11300-F (11th Cir.). On August 2, 2023, Bullard filed the second Section 2254 petition in this case. (Doc. 1) In Ground One, Bullard asserts that law enforcement officers violated his federal right to due process by destroying data on a hard drive that would have

supported an alibi defense. (Doc. 1 at 5, 13–16) He further asserts that trial counsel deficiently performed by not requesting the prosecutor to disclose the exculpatory evidence and by not presenting the evidence at trial. (Doc. 1 at 13–14) In Ground Two, he asserts that his convictions for possession of child pornography violated his right against double jeopardy. (Doc. 1 at 18–19) ANALYSIS Because Bullard filed his Section 2254 petition after the enactment of the

Antiterrorism and Effective Death Penalty Act, AEDPA applies. Lindh v. Murphy, 521 U.S. 320, 336 (1997). Bar on a Second or Successive Petition Under AEDPA, “before a petitioner may file a second or successive Section 2254 habeas petition, the petitioner first must obtain an order from [the court of

appeals] authorizing the district court to consider the petition.” Osbourne v. Sec’y, Fla. Dep’t Corrs., 968 F.3d 1261, 1264 (11th Cir. 2020) (citing 28 U.S.C. § 2244(b)(3)(A)). “Absent authorization from [the court of appeals], the district court lacks jurisdiction to consider a second or successive habeas petition.” Osbourne, 968 F.3d at 1264. “However, ‘where . . . there is a new judgment intervening between the two habeas

petitions, an application challenging the resulting new judgment is not second or successive[.]’” Osbourne, 968 F.3d at 1264 (quoting Magwood v. Patterson, 561 U.S. 320, 341–42 (2010)). “‘[T]he judgment that matters for purposes of Section 2244 is the judgment authorizing the petitioner’s confinement.’” Osbourne, 968 F.3d at 1265 (quoting Patterson v. Sec’y, Fla. Dep’t Corrs., 849 F.3d 1321, 1325 (11th Cir. 2017)).

Because this Court adjudicated Bullard’s earlier petition on the merits by dismissing the petition as time barred, Section 2244(b) requires Bullard to obtain permission from the court of appeals before filing a second or successive petition, unless the second amended judgment is a new judgment under Section 2244(b). Patterson, 849 F.3d at 1325 (“When his first federal petition was dismissed as untimely, Patterson lost his one chance to obtain federal habeas review of his 1998 judgment.”).

After this Court dismissed Bullard’s earlier Section 2254 petition, the post-conviction court granted in part Bullard’s motion to correct an illegal sentence. (Doc. 9-3 at 346–51) At the sentencing hearing, the trial judge departed downward and reduced Bullard’s sentence from sixty years in prison to twenty years in prison. (Doc. 9-3 at 373–76) In a sentencing order, the trial judge imposed the new sentences,

nunc pro tunc to August 9, 2010, the date of the original judgment. (Doc. 9-3 at 376) The second amended judgment is titled “Judgment Resentence to Twenty Years FSP, Nunc Pro Tunc to August 9, 2010.” (Doc. 9-3 at 378) The trial judge signed the second amended judgment on “August 4, 2021, Nunc Pro Tunc to August 9, 2010.”

(Doc. 9-3 at 381) The second amended sentence states “Amended Sentence per Hearing August 4, 2021, Defendant Resentenced to Twenty Years FSP, Nunc Pro Tunc to August 9, 2010.” (Doc. 9-3 at 382) Osbourne, 968 F.3d at 1266–67, holds that a petitioner’s amended judgment, entered nunc pro tunc to the date of the original judgment, relates back to the original

judgment and therefore is not a new judgment under Section 2244(b). In Osbourne, 968 F.3d at 1266 n.4, the Eleventh Circuit refused to review whether the state court properly entered the amended sentence, nunc pro tunc to the date of the original judgment: We note Florida law also provides that “when the court wholly omits an order or wishes to change it, the new order cannot be entered nunc pro tunc.” Riha’s Estate, 369 So. 2d at 404.

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