McCormick v. Stange

CourtDistrict Court, E.D. Missouri
DecidedJanuary 26, 2024
Docket1:23-cv-00168
StatusUnknown

This text of McCormick v. Stange (McCormick v. Stange) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCormick v. Stange, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

JOHN D. MCCORMICK, ) ) Petitioner, ) ) v. ) No. 1:23-CV-168 NCC ) BILL STANGE, ) ) Respondent. )

MEMORANDUM AND ORDER This matter is before the Court for review of Petitioner John D. McCormick’s response to the December 18, 2023 order directing him to show cause why his Petition Under 28 U.S.C. § 2254 for Writ of Habeas Corpus should not be dismissed. After reviewing and considering Petitioner’s response, the Court concludes that the Petition is untimely, and Petitioner has failed to show cause why it should not be dismissed as such. The Court will therefore dismiss this action without further proceedings, and will not issue a certificate of appealability. Background As explained in detail in the Court’s December 18, 2023 Order (ECF No. 6), incorporated herein, Petitioner filed the Petition after the expiration of the limitations period set forth in the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). Following is a brief summary. In the Petition, Petitioner specifies that he challenges the April 27, 2018 judgment entered in State v. McCormick, No. 17JE-CR00233-01 (23rd Jud. Cir. 2017), which became final for purposes of 28 U.S.C. § 2244(d)(1)(A) on May 7, 2018. Petitioner had one year from that date to file a Petition Under 28 U.S.C. § 2254 for Writ of Habeas Corpus, but he did not do so until (at the earliest) September 17, 2023. On October 20, 2021, after the expiration of the federal limitations period set forth in 28 U.S.C. § 2244(d)(1)(A), Petitioner filed a motion for post-conviction relief in the Circuit Court of Jefferson County, Missouri. McCormick v. State, No. 21JE-CC00722 (23rd Jud. Cir. 2021).1 The motion was untimely under applicable Missouri. On September 8, 2022, Petitioner filed a

motion titled Motion for Court to Accept Pro Se Motion as Timely Filed, asking the state circuit court to excuse his untimely filing. In support, Petitioner argued that because the transcript of his sentencing was unavailable, there was no way to confirm that the sentencing court had correctly advised him of his post-conviction rights, and the lack of the transcript would prejudice him. The state circuit court denied the motion after a September 9, 2022 hearing. In the December 18, 2023 Order, the Court noted the Petition appeared untimely, and directed Petitioner to show cause why it should not be dismissed. The Court explained that the Petition was filed after the expiration of the limitations period set forth in 28 U.S.C. § 2244(d)(1)(A). The Court determined that Petitioner’s October 20, 2021 post-conviction motion had no tolling effect because it was filed after the expiration of that limitations period,

and because the State court had rejected it as untimely. The Court also determined that nothing in the Petition suggested that any other subsection of § 2244(d)(1) could apply. Finally, the Court explained that even if Petitioner specified that he challenged the July 9, 2021 judgment reinstating the execution of his 20-year sentence, the Petition would be untimely. The Court directed Petitioner to show cause why the Petition should not be dismissed. On January 22, 2024, Petitioner filed a response titled “Petitioner’s Show Cause.” (ECF No. 7). Therein, Petitioner writes:

1 According to the “Case Header” tab on Missouri Case.net, the disposition of this case is now listed as “Not Disposed.” However, there has been no docket activity since the Circuit Court denied Petitioner’s motion to accept his untimely filing on September 9, 2022, and there is no indication that any matters remain pending for adjudication. It therefore appears that the case is in fact disposed. [illegible] is before the court upon review of Missouri [illegible] prisoner John D. McCormick’s petition Under 28 U.S.C. § 2254 for Writ of Habeas Corpus.

Petitioner respectfully requests that this honorable court grant his request to file out-of-time due to the court misinformating [sic] Petitioner and the circumstances outlined in the six pages enclosed.

(ECF No. 7). Petitioner avers nothing further. The six-page enclosure Petitioner references consists of a copy of the September 8, 2022 Motion for Court to Accept Pro Se Motion as Timely Filed that Petitioner filed in his State post-conviction action, and two letters Petitioner received from his Missouri State public defender, dated February 14, 2022 and August 3, 2022. The September 8, 2022 motion is described above. In the February 14, 2022 letter, counsel advised Petitioner that: “there might be some basis for arguing that the [State motion for post-conviction relief] should be deemed timely based on the court’s attempt to resentence you then vacate the revised sentence.” (ECF No. 7-1 at 5). In the August 3, 2022 letter, counsel advised Petitioner that she had not received transcripts of Petitioner’s April 27, 2018 sentencing hearing, or the July 9, 2021 proceeding at which the State court decided to reinstate Petitioner’s sentence. None of the materials Petitioner filed reference the timing of filing a federal petition for writ of habeas corpus, or any attempt to file such a petition. Discussion Rule 4 of the Rules Governing § 2254 Cases in the United States District Courts provides that a district court shall summarily dismiss a habeas petition if it plainly appears that the petitioner is not entitled to relief. Under 28 U.S.C. § 2244(d): (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.

Petitioner does not argue that his Petition is timely. Instead, Petitioner can be understood to ask this Court to apply the doctrine of equitable tolling to his untimely Petition, based on the circumstances described in the September 8, 2022 motion, and the two letters from his State public defender. The statute of limitations in 28 U.S.C. § 2244(d) is subject to the doctrine of equitable tolling. See Gassler v. Bruton, 255 F.3d 492, 495 (8th Cir. 2001) (explaining that equitable tolling may apply to an untimely 28 U.S.C. § 2254

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Bluebook (online)
McCormick v. Stange, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccormick-v-stange-moed-2024.