Pendleton v. Warden

CourtDistrict Court, N.D. Indiana
DecidedApril 27, 2022
Docket3:21-cv-00591
StatusUnknown

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

Bluebook
Pendleton v. Warden, (N.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

MARLON L. PENDLETON,

Petitioner,

v. CAUSE NO. 3:21-CV-591-JD-MGG

WARDEN,

Respondent.

OPINION AND ORDER Marlon L. Pendleton, a prisoner without a lawyer, filed a motion to reconsider the order denying the habeas petition under Fed. R. Civ. P. 60(b). This provision authorizes the court to relieve a party from a final judgment based on: “(1) mistake, inadvertence, surprise, or excusable neglect; (2) newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b); (3) fraud (whether previously called intrinsic or extrinsic), misrepresentation, or misconduct by an opposing party; or . . . (6) any other reason that justifies relief.” Fed. R. Civ. P. 60(b). “Reconsideration is not an appropriate forum for rehashing previously rejected arguments or arguing matters that could have been heard during the pendency of the previous motion.” Caisse Nationale de Credit Agricole v. CBI Industries, Inc., 90 F.3d 1264, 1270 (7th Cir. 1996). On August 12, 2021, Pendleton filed the habeas petition challenging his parole revocation. ECF 2. The court observed that the petition had a date of November 30, 2020, and that it contradicted itself as to whether he had presented the grounds for habeas relief to the State courts. ECF 7. As a result, the court granted Pendleton an opportunity to clarify the date of filing and his efforts to exhaust State court remedies.

Id. In response, Pendleton explained that he filed a habeas petition in State court on November 30, 2020, and that the Lake Superior Court declined to rule on the petition on June 17, 2021. ECF 6. The petitions filed with the Lake Superior Court and in this court both used this court’s form for federal habeas petitions and were identical except that, on the State court petition, Pendleton wrote “LAKE COUNTY SUPERIOR COURT” at the top of the first page. ECF 2, ECF 6-3 at 65-69. The order issued by the Lake Superior

Court indicated that it interpreted the petition as an improper attempt to file a successive petition for post-conviction relief challenging his conviction, or, alternatively, as an attempt to initiate proceedings with this court that was sent to the wrong address. ECF 2-1. On October 8, 2021, this court considered the information provided by Pendleton and found that the petition was untimely and dismissed this case. ECF 7.

In the motion to reconsider, Pendleton argues that the court should not have found his petition was untimely because the Lake Superior Court unreasonably interpreted his State court petition. In the order of dismissal, the court rejected this line of reasoning, noting that the Seventh Circuit Court of Appeals has held that courts should take an objective approach in determining whether an application for collateral

review was “properly filed” for purposes of statutory tolling under 28 U.S.C. § 2244(d)(2). ECF 7 at 2-4. As articulated by the Seventh Circuit: Whether a collateral attack is “properly filed” can be determined in a straightforward way by looking at how the state courts treated it. If they considered the claim on the merits, it was properly filed; if they dismissed it for procedural flaws such as untimeliness, then it was not properly filed.

Freeman v. Page, 208 F.3d 572, 576 (7th Cir. 2000). As noted in the order of dismissal, the order from the Lake Superior Court unequivocally demonstrates that it did not treat the State petition as a properly filed application for collateral review. Given the objective approach set forth in Freeman, the court declines to further assess the State court’s interpretation of the State petition. Pendleton argues that the court should reconsider its timeliness determination because the law librarian mailed a petition to the State courts without his signature or in forma pauperis documents and represented that she did not have forms available for State habeas petitions. He maintains that the federal petition is timely because this lack

of cooperation amounted to “State action in violation of the Constitution“ that prevented him from filing a timely habeas petition. To start, it is unclear that the law librarian’s actions as alleged by Pendleton amount to a constitutional violation. See Lewis v. Casey, 518 U.S. 343, 351 (1996) (actual injury requirement for interference-with- access-to-the-courts claims); Snyder v. Nolen, 380 F.3d 279, 291 (7th Cir. 2004) (“[A]n

allegation of simple negligence will not support a claim that an official has denied an individual of access to the courts.”). Further, Pendleton does not adequately explain how the law librarian prevented him from filing a timely habeas petition with this court; instead, the record reflects that he had access to this court’s form for habeas petition as well as the ability to send mail

to the courts and so could have initiated this case at least three months before the limitations period expired. See Conroy v. Thompson, 929 F.3d 818, 821 (7th Cir. 2019) (finding that the petitioner could not demonstrate that he was prevented from pursuing

federal habeas claims because he had filed numerous documents in State court); Ramirez v. Yates, 571 F.3d 993, 998 (9th Cir. 2009) (finding that the petitioner could not demonstrate that he was unable to prepare a federal habeas petition because he had filed other well-researched documents with various courts and “offer[ed] no explanation of how or why his restricted library access made it impossible for him to file a timely § 2254 petition but not . . . other substantial legal filings.”); Lloyd v. Van

Natta, 296 F.3d 630, 633 (7th Cir. 2002) (“[T]he plain language of the statute makes clear that whatever constitutes an impediment must prevent a prisoner from filing his petition.”) (emphasis in original). Though Pendleton decided to wait until the Lake Superior Court addressed the State petition, nothing in the record suggests that Pendleton was prevented from filing a federal habeas petition sooner. See Pace v.

DiGuglielmo, 544 U.S. 408, 416 (2005) (“A prisoner seeking state postconviction relief might avoid this predicament, however, by filing a protective petition in federal court and asking the federal court to stay and abey the federal habeas proceedings until state remedies are exhausted.”). Based on the foregoing, the court reaffirms its finding that the petition was untimely.

Pendleton also argues that the court should not have resolved the habeas petition because he sent it to this court as a courtesy copy of his State petition and did not intend to litigate it here.

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Related

Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Kenneth J. Lloyd v. John R. Vannatta
296 F.3d 630 (Seventh Circuit, 2002)
James R. Snyder v. Jack T. Nolen
380 F.3d 279 (Seventh Circuit, 2004)
Ramirez v. Yates
571 F.3d 993 (Ninth Circuit, 2009)
Bill Conroy v. Scott Thompson
929 F.3d 818 (Seventh Circuit, 2019)

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Bluebook (online)
Pendleton v. Warden, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pendleton-v-warden-innd-2022.