Kirby v. Warden, Madison Correctional Institution

District Court, S.D. Ohio·Decided May 15, 2025·No. 1:23-cv-00424·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI

BRYAN KIRBY,

Petitioner, : Case No. 1:23-cv-424

- vs - District Judge Douglas R. Cole Magistrate Judge Michael R. Merz

TOM WATSON, WARDEN, North Central Correctional Complex,

: Respondent. SUPPLEMENTAL REPORT AND RECOMMENDATIONS

This habeas corpus case was brought by Petitioner Bryan Kirby pro se under 28 U.S.C. § 2254 to obtain relief from his 2022 conviction in the Butler County Court of Common Pleas on charges of aggravated arson, aggravated burglary, and arson (Petition, ECF No. 1, PageID 1). It is before the Court on Petitioner’s Objections (ECF No. 35) to the pending Report and Recommendations (“Report”) recommending the Petition be dismissed with prejudice as untimely filed (ECF No. 32). District Judge Cole has recommitted the case for consideration of the Objections (ECF No. 36). The Petition pleads one ground for relief: Ground One: The trial court abuse [sic] its discretion. Supporting Facts: When it failed to hold a hearing on the motion of leave the Appellant filed. This violated the appellant’s right to be heard as the evident [sic] the appellant put forth met the requirement pursuant to Criminal Rule 33 as well as the Ohio Postconviction conviction statute dictate. (Petition, ECF No. 1, PageID 5). The Report recommended dismissal because the Petition was filed after expiration of the one-year statute of limitations enacted in 28 U.S.C. § 2244(d)(Report, ECF No. 32). Kirby made a claim that his actual innocence excused his untimely filing. The Report rejected that claim because the new evidence presented was not sufficient to meet the actual innocence standard adopted in Schlup v. Delo, 513 U.S. 298, 319 (1995). That is, it was not “exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence -- that was not presented at trial." Schlup, 513 U.S. at 324. The Report also noted that the Petition failed to state a claim for relief under the United States Constitution because habeas corpus does not extend to abuse of discretion claims. Abuse of discretion is not a denial of due process. Sinistaj

v. Burt, 66 F.3d 804 (6th Cir. 1995).

Petitioner’s Objections

Petitioner’s Objections begin by asserting that he has made “several substantial federal constitutional claims in his habeas corpus petition,” but does not say what they are beyond the one ground for relief he pleaded. He then states he will not address the claims in the order they were previously presented so that their new statement will be made clear and more precise (ECF No. 35, PageID 1477). Under Claim I he asserts the new evidence he has presented is sufficient to satisfy the

Schlup standard. Id. The new evidence to which he adverts is the evidence of existence of an impound lot operated by the Middletown Police Department and of service records of the burned Ford Explorer showing it had not been repaired in accordance with a vehicle recall. But that evidence is not “new” in the sense meant by Schlup. It was considered by the Twelfth District Court of Appeals on direct appeal and again on appeal from denial of Kirby’s motion for new trial. On the latter occasion that court said: ¶ 13 Kirby argues the trial court erred by denying his motion for leave to file a motion for a new trial because he put forth evidence that, prior to his trial taking place in the spring of 2019, there existed an impound lot that police could have used to store the Ford Explorer he was alleged to have set on fire. Kirby also argues the trial court erred by denying his motion for leave because the vehicle "had a recall that was not satisfied, and the trial attorney failed to investigate that point." However, after a full; and thorough review of the record, we find the trial court did not err by denying Kirby's motion, nor did the trial court err by making that decision without holding an evidentiary hearing. We instead agree with the trial court's decision finding the record devoid of any evidence indicating Kirby's motion was anything other than a frivolous filing. This is because, as the record indicates, it was no secret that the Ford Explorer was subject to a recall at the time of Kirby's trial. It was also no secret that there existed an impound lot that police could: have, in theory, used to store the fire damaged Ford Explorer after Kirby set the vehicle on fire. This holds true regardless of whether Kirby, or his trial attorney, were actually aware of these facts at the time Kirby's trial began.

(Judgment, State Court Record, ECF No. 23, Ex. 51, PageID 551). Kirby proceeds next to reargue his claim under California v. Trombetta, 467 U.S. 479 (1984), that the State destroyed material evidence when it did not keep the burned car. No recommendation on this point is included in the Report. Kirby’s labeled “Second Objection” is that the Report repeats the “untruthful placitude” [sic] that Kirby’s fire investigator conceded photographs of the burned vehicle were sufficient for his investigation (Objections, ECF No. 35, PageID 1482). That is simply not true. While the Report notes that Kirby spent a great deal of his Reply arguing his Trombetta claim, it principally noted that this argument did not address the timeliness issue. Kirby’s Third Objection reargues the merits of his state court motion for leave to file a motion for new trial, focusing on whether he was “unavoidably prevented” from discovering relevant facts. He writes: “The Magistrate Judge is clearly in error,” but then argues the error of the state trial court judge in not granting him a new trial or at least an evidentiary hearing on his motion for leave (Objections, ECF No. 35, PageID 1486, et seq.). Kirby’s Fourth Objection is that the trial judge’s abuse of discretion in denying a hearing

is a due process violation. Id. at PageID 1487-89. Kirby’s theory seems to be that any asserted constitutional violation related to the admission or consideration of evidence allows a federal habeas court to consider the excluded evidence in deciding actual innocence for statute of limitations purposes. Assuming for the sake of argument that that is true, it does not speak to the ultimate actual innocence question. As the Supreme Court wrote in McQuiggin We caution, however, that tenable actual-innocence gateway pleas are rare: “[A] petitioner does not meet the threshold requirement unless he persuades the district court that, in light of the new evidence, no juror, acting reasonably, would have voted to find him guilty beyond a reasonable doubt.” Schlup, 513 U. S., at 329, 115 S. Ct. 851, 130 L. Ed. 2d 808; see House, 547 U. S., at 538, 126 S. Ct. 2064, 165 L. Ed. 2d. 1 (emphasizing that the Schlup standard is “demanding” and seldom met”).

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

Kirby v. Warden, Madison Correctional Institution, (S.D. Ohio 2025).

Kirby v. Warden, Madison Correctional Institution (Kirby v. Warden, Madison Correctional Institution) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

California v. Trombetta
467 U.S. 479 (Supreme Court, 1984)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
House v. Bell
547 U.S. 518 (Supreme Court, 2006)
Fran Sinistaj v. Sherry Burt
66 F.3d 804 (Sixth Circuit, 1995)
McQuiggin v. Perkins
133 S. Ct. 1924 (Supreme Court, 2013)