Owens v. Clarke

CourtDistrict Court, E.D. Virginia
DecidedOctober 26, 2022
Docket3:22-cv-00394
StatusUnknown

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

Bluebook
Owens v. Clarke, (E.D. Va. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division KEITH OWENS, ) ) Petitioner, ) ) V. ) Civil Action No. 3:22-cv-394-HEH ) HAROLD CLARKE, ) ) Respondent. ) MEMORANDUM OPINION (Denying Motions) Keith Owens (“Petitioner”) is a Virginia state prisoner proceeding pro se and brings this petition pursuant to 28 U.S.C. § 2254 (“§ 2254 Petition,” ECF No. 4) challenging his conviction in the Circuit Court of Brunswick County, Virginia (“Circuit Court”). In his § 2254 Petition, Owens argues that he is entitled to relief based upon the following grounds:! Claim One: “Violation of 6th Amendment right to the effective representation of counsel.” (/d. at 5.) Claim Two: “Violation of 5th, 6th, and 14th Amendment right to representation, fair trial, due process, and equal protection of Jaws.” (/d. at 7.) Respondent Harold Clark (“Respondent”) initially moved to dismiss the § 2254 Petition as untimely or as procedurally defaulted, in the alternative. (ECF No. 15 at 3-8.)

The Court employs the pagination assigned to the parties’ submissions by the CM/ECF docketing system. The Court corrects the capitalization and punctuation in quotations from _ Owens’ submissions.

However, on September 19, 2022, the Court received a letter from Petitioner asking the

- Court to stay the proceedings. (ECF No. 18.) Petitioner indicates that: [t]he Va. Supreme Court has reversed their judgment that previously found my state writ untimely and restored that action to the docket. Therefore, while I exhaust my newly available state court remedies, I would ask this Court to abate all action on my federal habeas until resolution of the state court proceedings. (Id. at 1.) In response, Respondent filed a second Motion to Dismiss on the grounds that the § 2254 Petition is unexhausted. (ECF No. 21 at 3-4.) Owens has filed a response (ECF No. 22.) and this matter is now ripe for review. I. PROCEDURAL HISTORY Following a guilty plea, the Circuit Court convicted Owens of four drug distribution offenses and two firearm offenses. (ECF No. 15-1 at 1-2.) By Order entered November 21, 2019, the Circuit Court sentenced Owens to an active term of seventeen

- years of incarceration for the drug and firearm offenses. (/d. at 2, 4.)? Owens did not appeal.

On November 17, 2021, Owens filed a petition for a writ of habeas corpus in the Supreme Court of Virginia. (ECF No. 15-2.) On January 25, 2022, the Supreme Court of Virginia denied Owens’ petition for a writ of habeas corpus because it was untimely.

2 Owens had prior convictions from 2014 for which he had received partially suspended sentences. The Circuit Court revoked a previously imposed suspended sentence of four years, and only resuspended one year of that sentence, leaving Owens with an active sentence of three years in addition to the twenty years for the 2019 convictions. (See ECF No. 15-1 at 3.) From his current § 2254 Petition, it is unclear exactly which convictions Owens challenges.

(ECF No. 15-3.) On March 25, 2022, the Supreme Court of Virginia denied Owens’ motion for reconsideration of the judgment. (ECF No. 15-4.) Owens filed his § 2254 Petition in this Court on or around May 19, 2022. (ECF No. 1 at 13.) However, Owens clearly continued to litigate his habeas petition in the state courts. On September 12, 2022, the Supreme Court of Virginia granted Owens’ “motion to correct, amend or reverse judgment nunc pro tunc” and “the petition for a writ of habeas corpus [was] returned to the docket of pending cases.” (ECF No. 21-1 at 1.) The action remains pending before the Supreme Court of Virginia. Il. EXHAUSTION AND PROCEDURAL DEFAULT A. Applicable Law Before a state prisoner can bring a § 2254 petition in federal district court, the prisoner must first have “exhausted the remedies available in the courts of the State.” 28 U.S.C. § 2254(b)(1)(A). State exhaustion “is rooted in considerations of federal-state comity,” and in Congressional determination via federal habeas laws “that exhaustion of

. adequate state remedies will ‘best serve the policies of federalism.’” Slavek v. Hinkle, 359 F. Supp. 2d 473, 479 (E.D. Va. 2005) (quoting Preiser v. Rodriguez, 411 U.S. 475, 491-92 & n.10 (1973)). The purpose of the exhaustion requirement is “to give the State

an initial opportunity to pass upon and correct alleged violations of its prisoners’ federal rights.” Picard v. Connor, 404 U.S. 270, 275 (1971) (internal quotation marks omitted). Exhaustion has two aspects. First, a petitioner must utilize all available state remedies before he can apply for federal habeas relief. See O'Sullivan v. Boerckel, 526 U.S. 838, 844-48 (1999). As to whether a petitioner has used all available state remedies, the

statute notes that a habeas petitioner “shall not be deemed to have exhausted the remedies available in the courts of the State . . . if he has the right under the law of the State to raise, by any available procedure, the question presented.” 28 U.S.C. § 2254(c). The second aspect of exhaustion requires a petitioner to have offered the state courts an adequate “opportunity” to address the constitutional claims advanced on federal

- habeas. Baldwin vy. Reese, 541 U.S. 27, 29 (2004) (quoting Duncan v. Henry, 513 US. 364, 365 (1995)) (additional internal quotation marks omitted). “To provide the State with the necessary ‘opportunity,’ the prisoner must ‘fairly present’ his claim in each appropriate state court (including a state supreme court with powers of discretionary review), thereby alerting that court to the federal nature of the claim.” Jd. (quoting Duncan, 513 U.S. at 365-66). Fair presentation demands that a petitioner must present “*both the operative facts and the controlling legal principles’ associated with each claim” to the state courts. Longworth v. Ozmint, 377 F.3d 437, 448 (4th Cir. 2004) (quoting Baker v. Corcoran, 220 F.3d 276, 289 (4th Cir. 2000)). The burden of proving that a claim has been exhausted in accordance with a “state’s chosen procedural scheme” lies with the petitioner. Mallory v. Smith, 27 F.3d 991, 995-96 (4th Cir. 1994). In Virginia, to exhaust state remedies, a “petitioner must present the same factual and legal claims raised in the instant petition to the Supreme Court of Virginia either by way of (i) a direct appeal, (ii) a state habeas corpus petition, or (iii) an appeal from a circuit court’s denial of a state habeas petition.” Sparrow v. Dir., Dep't of Corr., 439 F. 2d 584, 587 (E.D. Va. 2006); see also Va. Code § 8.01-654(A)(1) (2022). “Whichever route the inmate chooses to follow, it is clear that [the inmate] ultimately

present his [federal habeas] claims to the Supreme Court of Virginia and receive a ruling from that court before a federal district court can consider them.” Banks v. Johnson, No. 3:07cv746—-HEH, 2008 WL 2566954, at *2 (E.D. Va. June 26, 2008) (first alteration in original) (quoting Graham v. Ray, No.

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Related

Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Baldwin v. Reese
541 U.S. 27 (Supreme Court, 2004)
Slavek v. Hinkle
359 F. Supp. 2d 473 (E.D. Virginia, 2005)
Baker v. Corcoran
220 F.3d 276 (Fourth Circuit, 2000)

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Bluebook (online)
Owens v. Clarke, Counsel Stack Legal Research, https://law.counselstack.com/opinion/owens-v-clarke-vaed-2022.