Manuel A. Santana del Rosario v. J. Bohinski

District Court, M.D. Pennsylvania·Decided August 7, 2026·No. 3:25-cv-01973·Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

MANUEL A. SANTANA DEL ROSARIO,

Petitioner, CIVIL ACTION NO. 3:25-cv-01973

v. (SAPORITO, J.)

J. BOHINSKI,

Respondent.

MEMORANDUM Manuel A. Santana del Rosario, incarcerated at SCI-Dallas, has filed a petition for writ of pursuant to 28 U.S.C. § 2254. Because he did not exhaust state court remedies as to any of the claims in the petition and has not established cause for a federal court to review these procedurally defaulted claims, the petition will be dismissed. I. STATEMENT OF THE CASE On October 26, 2022, in the Court of Common Pleas of Schuylkill County, a jury convicted Rosario of two counts of aggravated assault and three related offenses. Rosario was sentenced to seven to 15 years’ incarceration. , No. CP-54-CR-0000320-2022 (Schuylkill Cty. Ct. Com. Pl.). As summarized by the trial court and adopted by the Pennsylvania Superior Court on appeal, the case involved

a dispute between Rosario and Edwin Candelario, to whom Rosario owed money, at Rosario’s home: Upon their entry into the home, [Rosario] placed $50.00 on a table for Candelario to retrieve. Candelario picked up the money and he and his girlfriend left the home. However, [Rosario] followed Candelario and his girlfriend to their vehicle where he made a comment to Candelario’s girlfriend which annoyed Candelario. The latter told [Rosario] that if he needed to say something it should be said to Candelario. [Rosario] then asked Candelario to come back into his home so they could finish talking. Candelario agreed, and he and his girlfriend re-entered [Rosario’s] home, whereupon [Rosario] pulled out a gun, stuck it in Candelario’s face, grabbed Candelario by the neck, and told him to sit down. Candelario sat on a couch, with his girlfriend sitting next to him. [Rosario] sat in a chair directly in front of Candelario with the gun in his hand. Candelario asked [Rosario] what the problem was, and why [Rosario] had a gun pointed at him. Candelario told [Rosario] that they could just forget “about this,” and that “this never happened.” [Rosario] responded in Spanish, “Rat,” and told Candelario to get on his knees. Candelario got on his knees on the floor. [Rosario] then told Candelario to put his hands on his head, which he did. Candelario was then hit on the head by [Rosario], and he fell toward his girlfriend’s lap. As Candelario was trying to return to his original position, [Rosario] threw a punch at Candelario’s face with his fist. Candelario blocked the punch, got up and hurried to the front door of the premises in an effort to exit the house. Candelario found that the front door was locked. As Candelario was trying to unlock the door, he was shot once in the arm and once in [the] area of the rib cage by [Rosario]. . . . Investigating police officers who examined the scene of the shooting identified bullet strikes to the inside of the door to [Rosario’s] home, and interviewed [Rosario] and his wife who had been present at the time of the shooting. [Rosario] admitted at trial that he had shot Candelario, and that he had ordered Candelario to get on his knees at gunpoint. However, [Rosario] claimed that he would not have shot Candelario if [Candelario] had allowed [Rosario] to search him for weapons, [if Candelario] had not hit [Rosario] as he was getting up from the floor when [Rosario] had the gun pointed at Candelario, or if Candelario had not reached toward his pocket as he was trying to get out of the front door. No evidence produced at trial indicated that Candelario possessed any weapon the day of the shooting. , No. 1737 MDA 2022, 2023 WL 8666645, at *1- 2 (Pa. Super. Ct. 2023). On direct appeal, Rosario raised three issues: 1. Did the Commonwealth fail to establish sufficient evidence to support a conviction for the charge of aggravated assault? 2. Did the court err by imposing an aggravated range sentence without considering the mitigating circumstances raised in the pre-sentence report and by [Rosario]? 3. Did the charges of recklessly endangering arise from the same event as the aggravated assault for sentencing purposes and should a separate sentence not have been imposed? at *2. The Superior Court affirmed Rosario’s conviction on December 15, 2023, and the record does not indicate that he sought review by the

Pennsylvania Supreme Court. Rosario then filed a petition seeking collateral relief under Pennsylvania’s Post Conviction Relief Act (“PCRA”). (Doc. 9-3). The

court appointed counsel for Rosario, and counsel filed an amended petition limited to the question of whether a statement Rosario made to

police was voluntary. The trial court denied the petition on July 12, 2024. Rosario appealed to the Superior Court, attempting to raise the following issues:

1. Whether trial counsel was ineffective for failing to call character witnesses during [Rosario’s] trial? 2. Whether trial counsel was ineffective for failing to file a pretrial motion seeking to suppress [Rosario’s] pre-arrest confession? , No. 1074 MDA 2024, 2025 WL 1952577, at *2- 4 (Pa. Super. Ct. 2025).1 The court determined that both issues had been

1 While his PCRA appeal was pending before the Superior Court, Rosario filed a habeas petition in this court, which was dismissed without prejudice because it was a “mixed” petition presenting both exhausted (continued on next page) waived because Rosario had failed to adequately explain or develop them

and affirmed on that basis on July 16, 2025. . at 5-6. When the Court received this petition2 on October 20, 2025, Rosario’s petition for allowance of appeal to the Pennsylvania

Supreme Court remained pending as to his PCRA petition. The respondent sought dismissal for Rosario’s failure to exhaust his claims. (Doc. 9). However, on January 26, 2026, while this habeas petition was

pending, the Pennsylvania Supreme Court denied review of Rosario’s PCRA petition. , 353 A.3d 543 (Pa. 2026). A. Habeas Claims Presented

Rosario asserts the following grounds for relief3:

and unexhausted claims. , No. 3:24-cv-01814 (M.D. Pa., filed Oct. 22, 2024).

2 Contemporaneously with this case, Rosario also filed a civil rights complaint in which he sought release from state custody premised on his allegedly wrongful conviction. The assigned magistrate judge has recommended dismissal of that complaint. , No. 3:25-cv-01982 (M.D. Pa.).

3 After filing this petition, Rosario submitted a series of additional filings that allude to a wide variety of perceived issues with his criminal case. (Docs. 7, 11, 12, 14, 15). Although we have reviewed and considered these filings, Rosario is not permitted to use them to add new claims to his petition on a rolling basis. His grounds for relief are limited (continued on next page) • (1) “Police violation of right, improperly search without warrant suppress evidence and intechnical [sic] filed and improper complaint”;

• (2) “Admissibility of criminal record and impeachment by evidence of a criminal conviction involved dishonesty”;

• (3) “Lack of character evidence”;

• (4) “Due process malicious prosecution conspiracy allegation, hate crime from police department, claim bias against me intentionally.”

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

Manuel A. Santana del Rosario v. J. Bohinski, (M.D. Pa. 2026).

Manuel A. Santana del Rosario v. J. Bohinski (Manuel A. Santana del Rosario v. J. Bohinski) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Harris v. Nelson
394 U.S. 286 (Supreme Court, 1969)
Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Murray v. Carrier
477 U.S. 478 (Supreme Court, 1986)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
Bracy v. Gramley
520 U.S. 899 (Supreme Court, 1997)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
Karim Eley v. Charles Erickson
712 F.3d 837 (Third Circuit, 2013)
Burt v. Titlow
134 S. Ct. 10 (Supreme Court, 2013)
Ricky Leake v. Jeffrey Dillman
594 F. App'x 756 (Third Circuit, 2014)
Eric Norris v. Marilyn Brooks
794 F.3d 401 (Third Circuit, 2015)
Jeffrey Workman v. Superintendent Albion SCI
915 F.3d 928 (Third Circuit, 2019)
Shinn v. Martinez Ramirez
596 U.S. 366 (Supreme Court, 2022)