Randall Hutchison v. Warden, Correctional Reception Center

District Court, S.D. Ohio·Decided July 20, 2026·No. 2:25-cv-00281·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

RANDALL HUTCHISON, : Case No. 2:25-cv-281 : Petitioner, : : District Judge Michael H. Watson vs. : Magistrate Judge Kimberly A. Jolson : WARDEN, CORRECTIONAL : RECEPTION CENTER, : : Respondent. :

REPORT AND RECOMMENDATION

This is an action pursuant to 28 U.S.C. § 2254 for a writ of habeas corpus. (Doc. 29). Petitioner seeks release from confinement imposed as part of the judgment of a state court in a criminal action. (Id.). This matter is now before the Court on Respondent’s motion to dismiss the case on the grounds that it is time-barred (Doc. 50), to which Petitioner has filed a response in opposition (Doc. 86). The case is also before the Court on various motions filed by Petitioner, including for dismissal of the charges (Doc. 85), release (Docs. 87, 98, 102), discovery (Docs. 94, 96, 103–08), and other miscellaneous relief (Docs. 89, 91). For the reasons that follow, it is recommended that Respondent’s motion to dismiss be GRANTED and that Petitioner’s pending motions be DENIED as moot. I. PROCEDURAL HISTORY A. State Convictions and Sentence On October 18, 2016, after being found competent to stand trial (see Doc. 48, Ex. 5), Petitioner, through counsel, entered negotiated pleas of guilty to felonious assault of a police officer with a firearm specification, improper handling of a firearm in a motor vehicle, violation of a protection order, forgery, and possession of criminal tools. (Doc. 48, Ex. 17, at PageID 291– 92). On the same date, he also entered, through counsel, an “Alford” guilty plea, pursuant to North Carolina v. Alford, 400 U.S. 25 (1970), to attempted felonious assault with a firearm specification. (Id.). The trial court sentenced Petitioner to an aggregate term of twenty years (six and one half

years below the total aggregated possible sentence) to be served consecutively to a federal sentence Petitioner was serving in an unrelated matter. (Doc. 48, Exs. 17–18). B. Direct Criminal Appeal Petitioner did not timely appeal. (See Doc. 50, at PageID 1231). Instead, on October 31, 2016, he filed the first of three pro se motions to withdraw guilty plea. (Doc. 48, Exs. 19, 21–22). The trial court denied the motions on November 29, 2016. (Id., Ex. 24). On December 29, 2016, Petitioner, through newly appointed appellate counsel, filed a timely appeal from the denial of his motions. (Id., Ex. 25). He was also granted leave to file a delayed direct appeal from his convictions. (Id., Ex. 25). On January 11, 2018, the state appellate court affirmed the trial court

in all matters. (Id., Ex. 30). Petitioner did not seek further review in the Supreme Court of Ohio. (See Doc. 50, at PageID 1232). C. Post-Conviction Filings Between March 1, 2017 and December 17, 2024, Petitioner filed numerous, often duplicative, pro se motions for post-conviction relief and/or other collateral review in the trial court. (See Doc. 50, at PageID 1232–35). The filings are summarized below. On March 1 and June 21, 2017, Petitioner filed motions to withdraw his guilty plea, for resentencing, and for release on bail pending appeal. (Id., Exs. 31–32). On November 15, 2018, he filed a motion to suspend his sentence. (Id., Ex. 33). Although the record before the Court does not contain a trial court entry explicitly denying these motions, under Ohio law a motion is presumed denied when a trial court fails to rule on it. See State v. Olah, 767 N.E.2d 755, 760 n.2 (Ohio Ct. App. 2001) (and Ohio cases cited therein). The Court therefore presumes that Petitioner’s March 1, June 21, and November 15 motions were denied at least by September 13, 2021, when the trial court expressly denied Petitioner’s later filed March 18, 2020 motion to

withdraw guilty plea. (See Doc. 48, Exs. 34, 36). Indeed, by then, the trial court had already rejected three previous motions to withdraw guilty plea and had found, in its November 29, 2016 Order, that Petitioner was “merely experiencing ‘buyer’s remorse’ because he d[id] not like the sentence actually imposed.” (Id., Ex. 24, at PageID 357). On January 27, 2022, the Ohio Court of Appeals affirmed the September 13, 2021 Order. (Id., Ex. 40). Petitioner did not seek further review in the Supreme Court of Ohio. (See Doc. 50, at PageID 1233). Meanwhile, on July 19, 2021, Petitioner filed a motion for post-conviction relief, which also contained a request to withdraw guilty plea. (Doc. 48, Ex. 41). He refiled the motion on January 6, 2022. (Id., Ex. 42). Then, on January 24, 2022, Petitioner filed another motion for

post-conviction relief. (Id., Ex. 43). In an Order dated April 29, 2022, the trial court expressly denied the July 19 and January 6 motions. (Id. at Ex. 44). As above, the Court presumes that the January 24, 2022 motion, which alleged falsification of documents (see id., Ex. 43, at PageID 1077), an issue already raised in the January 6, 2022 motion (see id., Ex. 42, at PageID 861), was also denied at least by April 29, 2022. See Olah, 767 N.E.2d at 760 n.2. Petitioner appealed from the April 29, 2022 Order but his appeal was dismissed for want of prosecution on October 7, 2022. (Doc. 48, Ex. 48). Petitioner did not seek further review in the Supreme Court of Ohio. (See Doc. 50, at PageID 1234). In the meantime, on August 25, 2022, Petitioner filed a second appeal from the same April Order. (Doc. 48, Ex. 49). The Ohio Court of Appeals dismissed that appeal as untimely on November 2, 2022. (Id., Ex. 51). As before, Petitioner did not seek further review in state Supreme Court. (See Doc. 50, at PageID 1234). A few months later, on July 17, 2023, Petitioner filed a motion for leave/findings for discovery. (See Doc. 48, Ex. 58, at PageID 1154). A few months after that, he filed a January 8, 2024 motion to withdraw his guilty plea, a March 18, 2024 motion to withdraw his guilty plea and

to re-file his January 6, 2022 motion, and a November 20, 2024 pleading titled “Newly Discovered Evidence, Actual Innocence.” (Id., Exs. 52–54). On December 12, 2024, the trial court denied the motions. (Id., Ex. 56). The trial court found that the July 17, 2023 motion was actually an unsupported public records request and that the other motions were improper attempts by Petitioner to seek reconsideration of the court’s April 29, 2022 Order denying his previous motions to withdraw guilty plea. (Id. at PageID 1119–20). Petitioner did not appeal. (See Doc. 50, at PageID 1235). On December 17, 2024, Petitioner filed a pleading titled “Newly Discovered Evidence, Refile of the January 6, 2022 Motion.” (Doc. 48, Ex. 57). This motion remained pending at the

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Randall Hutchison v. Warden, Correctional Reception Center, (S.D. Ohio 2026).

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