Patterson v. Lapinskas

CourtDistrict Court, D. Alaska
DecidedApril 23, 2020
Docket3:20-cv-00007
StatusUnknown

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

Bluebook
Patterson v. Lapinskas, (D. Alaska 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA

TOMMIE PATTERSON, Petitioner, No. 3:20-cv-00007-JKS vs. ORDER [Re: Motion at Docket No. 13] WILLIAM LAPINSKAS, Superintendent, Spring Creek Correctional Center, Respondent. Tommie Patterson, a state prisoner proceeding pro se, filed a Petition for Writ of Habeas Corpus under 28 U.S.C. § 2254. Docket No. 1 (“Petition”). He concurrently filed a motion requesting the appointment of counsel. Docket No. 3. Noting that there is no constitutional right to counsel in federal habeas proceedings, see Lawrence v. Florida, 549 U.S. 327, 336-37 (2007) (citing Coleman v. Thompson, 501 U.S. 722, 756-57 (1991)), the Court denied the motion and stated it would not reconsider the request until it had an opportunity to thoroughly review Respondent’s answer, see Weygandt v. Look, 718 F.2d 952, 954 (9th Cir. 1983) (“In deciding whether to appoint counsel in a habeas proceeding, the district court must evaluate the likelihood of success on the merits as well as the ability of the petitioner to articulate his claims pro se in light of the complexity of the legal issues involved.”). Respondent answered the Petition and moved to dismiss it on timeliness grounds at Docket No. 9. At Docket No. 13, Patterson renews his request for counsel. -1- Because Respondent’s answer is limited to the issue of timeliness, the Court again determines that the appointment of counsel is not warranted in this case. The sole issue before this Court is whether Patterson timely filed his Petition, and if not, whether he is entitled to equitable tolling. Because Patterson himself is in the best position to address that issue, the interests of justice do not require that Patterson receive the assistance of counsel at this juncture. Under the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), 28 U.S.C. § 2254(d), there is a one-year limitations period in which a state prisoner may file a federal habeas petition challenging his or her state conviction: 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; ... 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. 28 U.S.C. § 2244(d)(1). Under the statute, “[t]his one-year limitations period is tolled during the pendency of a ‘properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim.’” Mardesich v. Cate, 668 F.3d 1164, 1169 (9th Cir. 2012). The Supreme Court explains that “[t]he time that an application for state post-conviction review is ‘pending’ includes the period between (1) a lower court’s adverse determination, and (2) the prisoner’s filing of a notice of appeal, provided that the filing of the notice of appeal is timely under state law.” Evans v. Chavis, 546 U.S. 189, 191 (2006) (emphasis in original) (citation omitted); id. at 192 (“If the filing of the appeal is timely, the period between the adverse lower court decision and the filing (typically just a few days) is not counted against the 1-year AEDPA time limit.”); but see Mitchell v. Valenzuela, 791 F.3d 1166, 1171 (9th Cir. 2015) (the statute of -2- limitations is not tolled, however, while an unexhausted petition under § 2254 is pending in federal court) (citing Rhines v. Weber, 544 U.S. 269, 274-75 (2005)). Thus, if Patterson has been timely and properly challenging his conviction in the state courts, the statute of limitations is tolled during any state proceedings. In support of his motion to dismiss, Respondent provides records of the Alaska state courts that reflect that the Alaska Supreme Court denied Patterson’s petition for hearing on August 24, 2011. Docket Nos. 9 at 22, 8-6 at 45. As Respondent notes in its answer, Patterson’s conviction became final on direct review 90 days later, when the time to file a petition for certiorari in the U.S. Supreme Court expired on November 22, 2011. See Jiminez v. Quarterman, 555 U.S. 113, 119 (2009); Spitsyn v. Moore, 345 F.3d 796, 798 (9th Cir. 2003). The one-year AEDPA statute of limitations therefore began to run on November 22, 2011. 28 U.S.C. § 2244(d)(1)(A). When Patterson filed his post-conviction relief application in Alaska Superior Court on May 25, 2012, 185 days of the one-year statute of limitations had run. Because Patterson’s post- conviction relief application was properly filed, the AEDPA statute of limitations was tolled from May 25, 2012, until February 15, 2019, when the Alaska Supreme Court denied his petition for hearing on his post-conviction relief application, Docket No. 8-9 at 31. The statute of limitations began to run again, however, after the Supreme Court’s denial on February 15, 2019. At that time, Patterson had 180 days left to file his federal habeas petition under the AEDPA, since 185 untolled days of the 365-day period had already elapsed before he filed his state post- conviction relief action. Patterson thus had until August 14, 2019, to timely file the instant action. Patterson did not file the instant Petition until January 2, 2020. Docket No. 1. It therefore appears that Patterson’s Petition is facially untimely. 1. Actual innocence may overcome the statute of limitations. The Supreme Court has held “that actual innocence, if proved, serves as a gateway through which a petitioner may pass” when the statute of limitations has expired. McQuiggin v. Perkins, 133 S. Ct. 1924, 1928 (2012) (citing Schlup v. Delo, 513 U.S. 298 (1995), and House v. -3- Bell, 547 U.S. 518 (1995)). This is because the Supreme Court has “held that the miscarriage of justice exception applies to state procedural rules, including filing deadlines.” Id. (quoting Coleman v. Thompson, 501 U.S. 722, 750 (1991)). But a “petitioner does not meet the threshold requirement unless he persuades the district court that, in light of the new evidence, no juror, acting reasonably, would have voted to find him guilty beyond a reasonable doubt.” Id. (quoting Schlup, 513 U.S. at 329) (internal citation marks omitted). This “standard is ‘demanding’ and seldom met.” Id. (quoting House, 547 U.S. at 538) (And “in making an assessment . . .

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Related

Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
House v. Bell
547 U.S. 518 (Supreme Court, 2006)
Evans v. Chavis
546 U.S. 189 (Supreme Court, 2006)
Lawrence v. Florida
549 U.S. 327 (Supreme Court, 2007)
Jimenez v. Quarterman
555 U.S. 113 (Supreme Court, 2009)
Doe v. Busby
661 F.3d 1001 (Ninth Circuit, 2011)
Destinni Mardesich v. Matthew Cate
668 F.3d 1164 (Ninth Circuit, 2012)
Anthony Lewis Whalem/hunt v. Rchard Early, Warden
233 F.3d 1146 (Ninth Circuit, 2000)
Fred G. Stillman v. A.A. Lamarque
319 F.3d 1199 (Ninth Circuit, 2003)
Sergey Spitsyn v. Robert Moore, Warden
345 F.3d 796 (Ninth Circuit, 2003)
Brian Keith Laws v. A.A. Lamarque, Warden
351 F.3d 919 (Ninth Circuit, 2003)
Jeffrey Ford v. Fernando Gonzalez
683 F.3d 1230 (Ninth Circuit, 2012)
McQuiggin v. Perkins
133 S. Ct. 1924 (Supreme Court, 2013)
Keith Mitchell v. Anthony Hedgpeth
791 F.3d 1166 (Ninth Circuit, 2015)
Roy v. Lampert
465 F.3d 964 (Ninth Circuit, 2006)

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Bluebook (online)
Patterson v. Lapinskas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patterson-v-lapinskas-akd-2020.