Perkins v. IDOC

District Court, S.D. Illinois·Decided October 1, 2025·No. 3:25-cv-00011·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

ANTONIO PERKINS,

Petitioner,

v. Case No. 25-CV-00011-SPM

RICHARD STEMPINSKI,

Respondent.

MEMORANDUM AND ORDER

McGLYNN, District Judge: Before the Court is an Amended Petition for Writ of Habeas Corpus pursuant to 28 U.S.C. § 2254 brought by Petitioner Antonio Perkins, an inmate housed at Jacksonville Correctional Center. (Doc. 12). In his Petition, Perkins argues that his state sentence violated the one-act, one-crime rule. (See id.). For the following reasons set forth, the Petition is DENIED. RELEVANT FACTS AND PROCEDURAL HISTORY

In November 2018, Perkins pleaded guilty to unlawful possession of a weapon by a felon and armed habitual criminal. (Doc. 25, Ex. G, ¶ 5). In exchange, the State dismissed an aggravated battery with a firearm charge as well as charges in an unrelated case. (Id.). The trial court sentenced him to two consecutive 10-year terms of imprisonment. (Id.). Perkins filed a motion to reduce his sentence and a motion for relief from judgment which the trial court recharacterized as a motion to withdraw his guilty plea. (Id., Ex. C, ¶ 3). The trial court denied the motions and the denial of his motion to withdraw his guilty plea was vacated on appeal because the trial court had not appointed counsel for petitioner. (Id. ¶¶ 3–5). On remand, petitioner filed a pro se affidavit, a pro se letter, and a counseled amended motion to withdraw his plea. (Id., Ex. G ¶¶ 11–13). His pro se letter argued that Illinois’s one-act, one-crime

doctrine required the court to vacate his conviction for unlawful possession of a weapon by a felon. (Id. ¶ 13). The trial court denied his motion to withdraw his guilty plea and made no mention of the one-act, one-crime argument raised in the pro se letter. (Id. ¶ 14). Perkins filed a direct appeal, which was denied by the Illinois Appellate Court, ruling that Perkins could not unilaterally modify the terms of his negotiated guilty

plea. (Id., Ex. D, ¶ 22). Cooper then filed leave to appeal to the Illinois Supreme Court, which was also denied, agreeing with the appellate court’s reasoning. (See id., Ex. H, pp. 4–5). Cooper also filed a petition for postconviction relief in the trial court while his direct appeal was pending, arguing that his convictions violated the one-act, one- crime rule and his counsel was ineffective for failing to raise the one-act, one-crime issue in his motion to withdraw his guilty plea. (See id., Ex. I, pp. 2–5). The trial court dismissed his petition, his appeal of that judgment is pending, see. (See id., Exs. J,

K). Perkins timely filed the instant Amended Petition pursuant to 28 U.S.C. § 2254 on March 11, 2025. (Doc. 12). Respondent Stempinski filed a Response on April 30, 2025. (See Doc. 24). Perkins filed a Reply on May 21, 2025. (See Doc. 26). APPLICABLE LEGAL STANDARDS This Petition is subject to the provisions of the Antiterrorism and Effective Death Penalty Act of 1996, Pub. L. No. 104-132, 110 Stat. 1214 [hereinafter AEDPA]. “The Antiterrorism and Effective Death Penalty Act of 1996 modified a federal habeas court’s role in reviewing state prisoner applications in order to prevent federal habeas ‘retrials’ and to ensure that state-court convictions are given effect to the extent

possible under law.” Bell v. Cone, 535 U.S. 685, 693 (2002). Habeas is not merely another round of appellate review. Instead, 28 U.S.C. § 2254(d) restricts habeas relief to cases where the state court determination “resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States” or “a decision that was based on an unreasonable determination of the facts in light

of the evidence presented in the State court proceeding.” Id. A judgment is “contrary to” Supreme Court precedent if the state court “contradicts the governing law set forth in [Supreme Court] cases.” Coleman v. Hardy, 690 F.3d 811, 814 (7th Cir. 2012) (citing Williams v. Taylor, 529 U.S. 362, 405 (2000)). A state court decision is an “unreasonable application of” clearly established federal law if the state court “identifies the correct governing legal rule from [Supreme Court] cases but unreasonably applies it to the facts of the particular state

prisoner’s case.” Coleman, 690 F.3d at 814 (quoting Williams, 529 U.S. at 407). Federal habeas review serves as “a guard against extreme malfunctions in the state criminal justice systems, not a substitute for ordinary error correction through appeal.” Harrington v. Richter, 562 U.S. 86, 102-03 (2011) (quoting Jackson v. Virginia, 443 U.S. 307, 332, n.5 (1979) (Stevens, J., concurring)). The Supreme Court has repeatedly emphasized that the Section 2254(d) standard “is intentionally ‘difficult to meet.’” Woods v. Donald, 135 S. Ct. 1372, 1376 (2015) (quoting White v. Woodall, 572 U.S. 415, 419 (2014); Metrish v. Lancaster, 569 U.S. 351, 358 (2013)). In addition to the requirement for timely filing under the AEDPA, a habeas

petitioner must clear two procedural hurdles before the Court may reach the merits of his habeas corpus petition: exhaustion of remedies and procedural default. Bolton v. Akpore, 730 F.3d 685, 694-696 (7th Cir. 2013). Before seeking habeas relief, a petitioner is required to bring his claim(s) through “one complete round of the State’s established appellate review process” because “the exhaustion doctrine is designed to give the state courts a full and fair opportunity to resolve federal constitutional claims

before those claims are presented to the federal courts.” O’Sullivan v. Boerckel, 526 U.S. 838, 845 (1999); see also 28 U.S.C. § 2254(c). Under the Illinois two-tiered appeals process, petitioners such as Perkins must fully present their claims not only to an intermediate appellate court, but also to the Illinois Supreme Court, which offers discretionary review in cases such as this one. O’Sullivan v. Boerckel, 526 U.S. 838, 845 (1999); see also 28 U.S.C. § 2254(c). If Petitioner has pursued his state-court remedies to exhaustion, the claims

may nevertheless be barred by procedural default. See Perruquet v. Briley, 390 F.3d 505, 514 (7th Cir. 2004). “[W]hen the habeas petitioner has failed to fairly present to the state courts the claim on which he seeks relief in federal court and the opportunity to raise that claim in state court has passed, the petitioner has procedurally defaulted that claim.” Id.

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