Morehouse v. NHSP

2002 DNH 072
CourtDistrict Court, D. New Hampshire
DecidedMarch 25, 2002
DocketCV-01-93-B
StatusPublished

This text of 2002 DNH 072 (Morehouse v. NHSP) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morehouse v. NHSP, 2002 DNH 072 (D.N.H. 2002).

Opinion

Morehouse v. NHSP CV-01-93-B 03/25/02 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Patrick Morehouse

v. Civil No. 01-93-B Opinion No. 2002 DNH 072 Warden, NH State Prison

MEMORANDUM AND ORDER

On March 16, 2001, Patrick Morehouse filed a federal habeas

corpus petition challenging his 1981 conviction for attempted

first degree murder. The Warden of the New Hampshire State

prison has moved to dismiss the petition on the ground that it is

barred by the one-year statute of limitation that governs habeas

corpus claims. See 28 U.S.C. § 2244(d)(1).

BACKGROUND

Morehouse was found guilty of attempted first degree murder

in the Hillsborough County Superior Court on May 14, 1981.1

1 Morehouse was first convicted in 1979. The New Hampshire Supreme Court vacated the initial conviction, however, because it determined that the trial court gave the jury an erroneous reasonable doubt instruction. See State v. Morehouse, 120 N.H. 738, 744-45 (1980). Shortly thereafter, he was sentenced to a prison term of not more

than 30 years, nor less than 10 years. The New Hampshire Supreme

Court summarily affirmed his conviction and sentence on August

25, 1981.2

Morehouse first attempted to collaterally attack his 1981

conviction by filing a habeas corpus petition with this court on

March 6, 1996. He claimed that his conviction should be vacated

because: (1) his trial counsel was ineffective; (2) the

prosecution presented insufficient evidence to support his

conviction; (3) the trial court violated his right to due process

of law by giving him an enhanced sentence based on the "cruelty

and depravity" of his crime; (4) he was not notified prior to the

trial that he could face an enhanced sentence; (5) the sentencing

judge erred in failing to specify the facts on which he relied in

2 Before acting on Morehouse's appeal, the supreme court directed his appellate counsel to "file a memorandum explaining why the issues in this case are different from those considered by the court in [Morehouse's appeal of his first conviction]." Counsel responded by informing the court that "the issues which would be briefed and argued in the [second] appeal would be identical to those argued and briefed in [the first appeal]." Because the court had previously rejected the issues Morehouse intended to raise in his second appeal, the court apparently determined that it could resolve the second appeal without further briefing.

- 2 - issuing the enhanced sentence; and (6) his appellate counsel was

ineffective.

On May 16 , 1996, the Magistrate Judge directed Morehouse to

file an amended petition demonstrating that he had exhausted

state court remedies with respect to his six claims for relief.

In response, Morehouse asked the court to dismiss his ineffective

assistance claims without prejudice and determine that he had

exhausted his remaining claims. The Magistrate Judge granted his

request on August 27, 1996.

On December 10, 1996, Morehouse filed a motion asking the

court to reinstate his dismissed ineffective assistance claims

and allow him to add a new claim that the New Hampshire Supreme

Court had violated his right to due process of law by summarily

affirming his conviction. I denied the motion because I

determined that I could not act on his petition if I allowed it

to include the unexhausted claims.

Morehouse renewed his request to amend his petition to

include the unexhausted claims at a hearing on July 30, 1997.

Although I informed Morehouse that I would have to dismiss his

entire petition if I granted his request, he nevertheless

- 3 - insisted that I permit him to amend his petition to include the

unexhausted claims so that he could immediately appeal my order

dismissing his petition. Ultimately, I granted his motion to

amend and dismissed his petition because it contained unexhausted

claims. The First Circuit Court of Appeals rejected Morehouse's

appeal on December 17, 1997.

Morehouse filed a certiorari petition with the New Hampshire

Supreme Court on December 29, 1997, raising several claims he had

included in his federal habeas corpus petition as well as several

new claims. After the supreme court rejected his petition,

Morehouse filed a second habeas corpus petition with this court

on May 11, 1998. Judge McAuliffe ultimately dismissed this

petition on April 9, 1999 because he determined that Morehouse's

certiorari petition did not satisfy the exhaustion requirement.

The First Circuit Court of Appeals affirmed Judge McAuliffe's

ruling on September 17, 1999.

Morehouse filed a habeas corpus petition in the Merrimack

County Superior Court on September 24, 1999. The Superior Court

dismissed his petition and the New Hampshire Supreme Court

declined to hear his appeal on August 21, 2000.

- 4 - Morehouse filed his current habeas corpus petition with this

court on March 16, 2001.

ANALYSIS

Congress enacted the Antiterrorism and Effective Death

Penalty Act ("AEDPA") in 1996. The Act, which went into effect

on April 24, 1996, included a one-year statute of limitations for

habeas corpus petitions. See 28 U.S.C. § 2 2 4 4 (d)(1). Because

Morehouse's conviction became final before Congress enacted

AEDPA, the one-year limitation period for his claims began to run

when AEDPA went into effect. See Currie v. Matesanz, 2002 WL

226925 at *2 (1st Cir. 2002). Morehouse thus had until April 24,

1997 to file his habeas corpus petition.

AEDPA provides that "[t]he 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

section." 28 U.S.C. § 2244(d)(2)(emphasis added). While this

statutory tolling provision covers periods in which a collateral

challenge is pending in state court, it does not apply to

- 5 - challenges initiated in federal court. Neverson v. Bissonnette,

261 F.3d 120, 125 (1st Cir. 2001). Morehouse accordingly cannot

rely on AEDPA's statutory tolling provision because a federal

habeas corpus petition is not covered under the provision and he

did not attempt to challenge his conviction in state court until

after the limitation period had expired. Thus, Morehouse's

current petition will be time-barred unless he can demonstrate

that the limitation period should be equitably tolled during the

pendency of his first federal habeas corpus proceeding.

The First Circuit has not yet determined whether a habeas

corpus petitioner can ever rely on equitable tolling to save a

habeas corpus claim that is otherwise barred by AEDPA's statute

of limitation. See Donovan v. State of Maine, 276 F.2d 87, 92

(1st Cir. 2002); Neverson, 261 F.3d at 127. The court has held,

however, that "equitable tolling, if available at all, is the

exception rather than the rule; resort to its prophylaxis is

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Related

Neverson v. Bissonnette
261 F.3d 120 (First Circuit, 2001)
Currie v. Matesanz
281 F.3d 261 (First Circuit, 2002)
Lora Belle Johnson v. United States
276 F.2d 84 (Fourth Circuit, 1960)
Charles C. Delaney III v. James Matesanz
264 F.3d 7 (First Circuit, 2001)
Marilynn R. Malcom v. Alice Payne
281 F.3d 951 (Ninth Circuit, 2002)
State v. Morehouse
424 A.2d 798 (Supreme Court of New Hampshire, 1980)

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