Paige v. Holloway

CourtDistrict Court, M.D. Tennessee
DecidedJanuary 29, 2025
Docket3:23-cv-01102
StatusUnknown

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

Bluebook
Paige v. Holloway, (M.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

JAMES ANDREW PAIGE, ) ) Movant, ) ) No. 3:23-cv-01102 v. ) Judge Trauger ) JAMES M. HOLLOWAY, ) ) Respondent. )

MEMORANDUM OPINION AND ORDER

The movant, James Andrew Paige (“Paige” or “the movant”), has filed a pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254, challenging his state court conviction out of the Davidson County Criminal Court in Nashville, Tennessee on three counts of rape. On June 17, 2024, the court dismissed the petition for a writ of habeas corpus to allow for the exhaustion of state remedies. (Doc. No. 15.) The movant, a state prisoner, has filed a motion to reconsider, (Doc. No. 16.), a supplemental motion to reconsider, (Doc. No. 20.), and a motion for an evidentiary hearing. (Doc. No. 24). On this court’s order (Doc. No. 21), the respondent filed a response to the motion for reconsideration. (Doc. No. 23). For the reasons that follow, the motion for reconsideration, the supplemental motion to reconsider, and the motion for an evidentiary hearing are denied. I. Background Paige filed an amended pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court ordered Paige to show cause why the petition should not be dismissed as untimely. (Doc. No. 13.) In response, Paige filed a “motion to show cause.” (Doc. No. 14). Therein, Paige stated that he was in the process of exhausting state remedies. Id. More precisely, Paige stated that he was still litigating his motion for a new trial (which had been pending since 2021), and, upon receiving a ruling, he intended to file a direct appeal. Id. The court dismissed the petition without prejudice because Paige had yet to exhaust his claims in the state courts. (Doc. No. 15). II. The motion and supplemental motion for reconsideration.

Paige in his motion for reconsideration and in his supplemental motion for reconsideration asks to be excused from exhausting his state court remedies on the ground that his motion for a new trial had been lingering for over three years in the state courts and this delay excuses him from the exhaustion requirement. Local Rule 7.01 provides the regulations related to filing motions in the Middle District of Tennessee. Local Rule 7.01(b) allows a party to file a motion to reconsider the Court’s ruling within fourteen (14) days after service of the order reflecting the action of the Judge. However, notwithstanding any other provisions of this rule, the prevailing party shall not respond to a motion to reconsider under this section unless the Court orders a response.

Local Rule 7.01(b). As an initial matter, it appears that Paige’s motion for reconsideration is untimely. The court dismissed the petition on June 17, 2024. The motion for reconsideration is signed and dated July 27, 2024. Under the “prison mailbox rule,” submissions by pro se petitioners are considered filed at the moment of delivery to prison officials for mailing. See Houston v. Lack, 487 U.S. 266, 271–72 (1988). Paige has sworn, under penalty of perjury, that he presented his motion for reconsideration to prison officials on July 27, 2024, thus, the court will accept that date as the filing date, under the prison mailbox rule. See e.g. Miller v. Collins, 305 F.3d 491, 497-98 (6th Cir. 2002). However, even giving Paige the benefit of the prison mailbox rule, the motion for reconsideration was not timely filed. Timeliness issues aside, Paige is also not entitled to reconsideration of the court’s summary dismissal order because the delays in adjudicating his motion for a new trial do not excuse him from exhaustion. Although a futility exception to the exhaustion requirement exists, See Duckworth v.

Serrano, 454 U.S. 1, 3 (1981), a habeas petitioner is nonetheless required to demonstrate that all available state court remedies have been exhausted or that exceptional circumstances exist which would make exhaustion unnecessary. Doty v. Lund, 78 F. Supp. 2d 898, 901 (N.D. Iowa 1999). Some courts have excused a habeas petitioner’s failure to exhaust his state court remedies where the petitioner shows an “inordinate delay” in the state court’s resolution of the petitioner’s postconviction motion. Johnson v. Bauman, 27 F.4th 384, 391 (6th Cir. 2022) (citing Workman v. Tate, 957 F.2d 1339, 1344 (6th Cir. 1992) (collecting cases)). Nonetheless, “a lengthy proceeding, while in some instances lamentable, does not always leave a petitioner incapable of securing his rights—that is, in the words of the statute, does not necessarily imply that ‘circumstances’ beyond the petitioner’s control have rendered the ‘process ineffective to protect [his] rights[.]”’ Id. (citing

28 U.S.C. § 2254(b)(1)(B)(ii)). The Sixth Circuit has indicated that nothing in the habeas statute excuses the exhaustion of state court remedies merely because of a delay in the state court process. Id., at 391-93. Although a petitioner’s failure to exhaust his claims may be excused where “circumstances exist that render [the state’s corrective] process ineffective to protect the rights of the applicant,” Id. at 388 (quoting § 2254(b)(1)(B)(ii)), the Sixth Circuit found that “the inordinate delay exception, if taken at face value, could exceed the statutory ‘ineffective’ standard, expanding § 2254(b)(1)(B)(ii)’s scope beyond both its text as well as the preexisting exceptions that the [habeas] statute codified.” Id., at 394. Although the Sixth Circuit in its prior cases had failed to “explicitly define” what an inordinate delay means, it never held that a petitioner demonstrated “inordinate delay” through delay alone. Id. Secondly, “a failure to exhaust may be excused only if the state is responsible for the delay.” Johnson, 27 F.4th at 394. The Sixth Circuit indicated that the court had “applied these two

guideposts…in a manner that aligns with the statute’s original meaning as well as the common law exhaustion doctrine that preceded the statute.” Id. Paige has failed to show that the delays in adjudicating his state motion for a new trial present exceptional circumstances that would justify excusing the exhaustion of state court remedies. Johnson v. Bauman, 27 F.4th at 395. The motion for a new trial remained pending in the state trial court for three years; however, the case did not sit idle in the state courts. Id. On November 29, 2021, trial counsel filed a motion for new trial and requested permission to file an amended motion for new trial at an appropriate time. (Respondent’s Attachment 4, Doc. No. 23-4). Public information available through the Davidson County Criminal Court Records System demonstrates that the motion for new trial evidentiary hearing was continued numerous

times. (Respondent’s Attachment 2, Doc. No. 23-2). Records obtained reveal that the appointment order appointing post-trial counsel to represent Paige with respect to his motion for a new trial was signed on May 26, 2023. (Respondent’s Attachment 5, Doc. No. 23-5). Thereafter, post-trial counsel filed an amended motion for new trial on August 30, 2024. (Respondent’s Attachment 6, Doc. No. 23-6).

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Related

Duckworth v. Serrano
454 U.S. 1 (Supreme Court, 1981)
Houston v. Lack
487 U.S. 266 (Supreme Court, 1988)
Daniel Workman v. Arthur Tate, (Workman I)
957 F.2d 1339 (Sixth Circuit, 1992)
Ralph Miller v. Terry Collins, Warden
305 F.3d 491 (Sixth Circuit, 2002)
Sedley Alley v. Ricky Bell
307 F.3d 380 (Sixth Circuit, 2002)
Frank E. Adams v. Flora J. Holland, Warden
330 F.3d 398 (Sixth Circuit, 2003)
Doty v. Lund
78 F. Supp. 2d 898 (N.D. Iowa, 1999)
State v. Rockwell
280 S.W.3d 212 (Court of Criminal Appeals of Tennessee, 2007)
Andrew Johnson v. Catherine Bauman
27 F.4th 384 (Sixth Circuit, 2022)
Dillon v. Hutchinson
82 F. App'x 459 (Sixth Circuit, 2003)

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Bluebook (online)
Paige v. Holloway, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paige-v-holloway-tnmd-2025.