Michael E. Casey v. Jay Forshey, Warden, Noble Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedApril 6, 2026
Docket2:25-cv-00505
StatusUnknown

This text of Michael E. Casey v. Jay Forshey, Warden, Noble Correctional Institution (Michael E. Casey v. Jay Forshey, Warden, Noble Correctional Institution) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael E. Casey v. Jay Forshey, Warden, Noble Correctional Institution, (S.D. Ohio 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

MICHAEL E. CASEY,

Petitioner, : Case No. 2:25-cv-00505 - vs - District Judge James L. Graham Magistrate Judge Michael R. Merz

JAY FORSHEY, WARDEN, Noble Correctional Institution,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case was brought pro se by Petitioner Michael Casey under 28 U.S.C. § 2254 to obtain relief from his conviction in the Guernsey County Court of Common Pleas for possession of cocaine (Petition, ECF No. 5, PageID 40). It is ripe for decision on the Petition, the State Court Record (ECF No. 14), the Return of Writ (ECF No. 15), and Petitioner’s Traverse (ECF No. 20). The Magistrate Judge reference in the case was recently transferred to the undersigned to help balance the Magistrate Judge workload in the District (ECF No. 21).

Litigation History

On May 23, 2022, a Guernsey County Grand Jury indicted Petitioner on one count of permitting drug abuse, in violation of Ohio Revised Code § 2925.13(B), (C)(3)(a); one count of possession of cocaine, in violation of Ohio Revised Code § 2925.11(A), (C)(4)(f) as a first degree felony; and one count of possession of cocaine, in violation of Ohio Revised Code § 2925.11(A), (C)(4)(d) as a second degree felony. On August 18, 2022, Petitioner withdrew his former plea of not guilty, and entered a plea of guilty to the one count of possession of cocaine set forth in Count Three of the Indictment. Casey did not take a direct appeal. However, on August 30, 2023, Casey filed pro se a petition for post-conviction relief, alleging ineffective assistance of trial counsel

(State Court Record, ECF No. 14, Exhibit 8). The trial court denied the petition and Casey appealed to the Ohio Court of Appeals for the Fifth District which affirmed. State v. Casey, 2024-Ohio-746 (Ohio App. 5th Dist. Feb. 28, 2024)(Casey I). The Ohio Supreme Court declined to exercise jurisdiction over a subsequent appeal. State v. Casey, 174 Ohio St. 3d 1506 (Jun. 25, 2024). On November 27, 2023, while the appeal of denial of his prior post-conviction petition was pending, Casey filed pro se a motion to set aside his conviction. (Motion, State Court Record, ECF No. 14, Ex. 19). The Common Pleas Court denied the Motion and Casey again appealed. The Fifth District found Casey did not meet the standard for withdrawal of a guilty plea after sentencing, to wit, a showing of manifest injustice. State v. Casey, 2024-Ohio-5284 (Ohio App. 5th Dist. Nov. 5, 2024). The Ohio Supreme Court declined to exercise jurisdiction over a

subsequent appeal. State v. Casey, 177 Ohio St. 3d 1455 (Mar. 5, 2025). Casey then filed his Petition in this Court, pleading one ground for relief:

Ground One: Petitioner was denied due Process and Effective Assistance of Trial Counsel.

Supporting Facts: After Petitioner pled guilty on trial counsel’s advice, newly discovered evidence that resulted from Petitioner’s wife’s trial counsel[‘s] having the crack cocaine reweighed with the water collected with it by police. This newly discovered evidence showed Petitioner and his wife possessed less than 11 grams of crack cocaine (while still wet), which shows Petitioner is not guilty of the level of offense he was advised by trial counsel to plead guilty to. Petitioner’s trial counsel provided ineffective assistance by failing to have the crack cocaine weighed separate from water and packaging, and for advising Petitioner to plead guilty to a level of offense greater than that which he could have been convicted in a trial by jury; and Petitioner was denied Due Process as a result, and where the trial court refused to set aside or invalidate the guilty plea to allow Petitioner to plead guilty to the proper offense level.

(Petition, ECF No. 5, PageID 44).

Timeliness of the Petition In the Return, Respondent asserts that this action is barred by the statute of limitations.

The applicable statute of limitations Congress in the Antiterrorism and Effective Death Penalty Act of 1996 (Pub. L. No 104- 132, 110 Stat. 1214)(the "AEDPA") enacted the first statute of limitations for habeas corpus cases challenging state court convictions under 28 U.S.C. § 2254. That statute is codified at 28 U.S.C. § 2244(d) and provides: (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.

(2) The time during which a properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim is pending shall not be counted toward any period of limitation under this subsection.

Application

Habeas petitioners are instructed by the Standard Form for § 2254 Petitions that: “18. If your judgment of conviction became final over a year ago, you must explain why the one-year statute of limitations as contained in 28 U.S.C. § 2244(d) does not bar your petition.” Although Casey copied that language into the Petition he filed, he failed to respond to this instruction (Petition, ECF No. 5, PageID 52). In the Return, Respondent claims the Petition is time-barred under § 2244(d)(1)(A), arguing that because Casey did not take a direct appeal, his conviction became final on the last day he could have done so, November 30, 2022. By this calculation, the statute began to run on that date and expired one year later on December 1, 2023. The Petition was not filed here until May 1, 2025, when Casey placed it in the prison mailing system. Thus the statute would have expired a year and a half before Casey filed. However, the running of the statute is tolled under § 2244(d)(2) during the pendency of any properly-filed collateral attack on the judgment. After the statute began to run on November 30, 2022, Casey filed his Petition for Post-Conviction Relief on August 30, 2023. Respondent concedes this was a properly filed collateral attack, so the statute was tolled until that proceeding was complete with the denial of review by the Ohio Supreme Court on March 5, 2024. However, in the meantime, Casey filed his Motion to Vacate. Respondent also concedes that was a properly filed collateral attack on the judgment which was not complete until the Supreme Court denied review of the Fifth District’s denial of relief on March 5, 2025. Thus the statute was tolled from the filing of the post-conviction petition on August 30, 2023, to the last Supreme Court denial of review on March 5, 2025. The statute ran from November 30, 2022, until August 30, 2023 – 273

days. It then began to run again on March 5, 2025, and would have expired ninety-two days later.

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Michael E. Casey v. Jay Forshey, Warden, Noble Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-e-casey-v-jay-forshey-warden-noble-correctional-institution-ohsd-2026.