Richards v. Warden, Madison Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedApril 7, 2025
Docket2:23-cv-02595
StatusUnknown

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

Bluebook
Richards v. Warden, Madison Correctional Institution, (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

KENDALL K. RICHARDS, :

Petitioner, : Case No. 2:23-cv-3544 Consolidated with 2:23-cv-2595 : - vs - District Judge Algenon L. Marbley : Magistrate Judge Michael R. Merz

JENNY HILDEBRAND, Warden, :

Respondent. : DECISION AND ORDER

This habeas corpus case under 28 U.S.C. § 2254 is before the Court on Petitioner’s Objections (ECF No. 19) to the Magistrate Judge’s Report and Recommendations recommending dismissal with prejudice (the “Report,” ECF No. 18). As required by 28 U.S.C. § 636(b)(1) and Fed.R.Civ.P. 72(b), the Court has reviewed de novo the Report with particular attention to those portions objected to by Petitioner. Having done so, the Court finds the objections are without merit and they are OVERRULED for the reasons set forth below. In his Traverse, Petitioner, who is litigating this case with the assistance of counsel, withdrew his First, Third, and Fourth Grounds for Relief, leaving only the Second which reads as follows: Ground Two: Ineffective Assistance of Appellate Counsel

Supporting Facts: Appellate Counsel’s decision to voluntarily dismiss Petitioner’s timely-filed appeal and subsequently file an untimely appeal has deprived Petitioner of any meaningful opportunity for appellate review.

(Amended Petition, ECF No. 10, PageID 63). Under Ohio law a claim of ineffective assistance of appellate counsel must be brought by way of an Application for Reopening the Appeal under Ohio R. App. P. 26(B)(Report, ECF No. 18, PageID 884, citing State v. Davis, 119 Ohio St. 3d 422, 427 (2008), applying and explaining State v. Murnahan, 63 Ohio St. 3d 60 (1992)). Rule 26(B) sets a time limit for filing the Application: ninety days “from the journalization of the appellate judgment [sought to be

reopened] unless the applicant shows good cause for filing at a later time.” The judgment sought to be reopened had been journalized on February 3, 2021. (Entry, State Court Record, ECF No. 9-5, Ex. 65, ¶ 6. Ninety days later was May 4, 2021. Petitioner’s 26(B) Application was not filed until November 6, 2022 (Application, State Court Record, ECF No. 9-5, Ex. 63). In the Application, Richards acknowledged it was untimely, but sought to show good cause for the late filing by contending it was caused by appellate counsel’s ineffectiveness and his own bout with cancer. The appellate court rejected this contention, holding: (¶8) In the case sub judice, we do not believe that appellant established good cause for failing to file his application within 90 days of our decision . [footnote omitted] Appellant has not shown that anything prevented him from filing an application to reopen within 90 days of our decision. In fact, we note that during that time period, counsel represented appellant and counsel filed a second notice of appeal rather than an application to reopen the first appeal. See generally State v. Keith, 119 Ohio. St. 3d 161, 2008-Ohio-3866, 892 N.E.2d 912, ¶ 7, quoting State v . Gumm, 103 Ohio St. 3d 162 , 2004-Ohio-4755, 814 N.E.2d 861 ¶ 8 (when defendant represented by counsel; defendant "could have attempted to obtain other counsel to file his application'' or "could have filed an application himself, but defendant could not '''igno.re the rule‘s filing deadline'”).

(¶9) Moreover, appellant's assertion that he has battled cancer since April 2021 is not sufficient to establish good cause. State v. Wilkins, 8th Dist. Cuyahoga No. 88389, 2012-0hio-3681, ¶ 9 ("applicant's own physical illness is not necessarily good cause for the untimely filing of an application for reopening," but instead, ''the appellant must establish that the illness prevented him or her from filing a timely application''); State v. Morris, 10th Dist. Franklin No. 0SAP- 1032, 2010-0hio-786, ¶ 10 (finding applicant's alleged diagnosis and classification as "seriously mentally ill" did not provide support for his claim that his mental health issues prevented him from filing a timely application).

(Opinion, State Court Record, ECF No. 9-5, PageID 530-31.)

The Report reads this language as rejecting Petitioner’s excuses for untimely filing and denying Petitioner’s 26(B) Application on that basis. The Report therefore found Petitioner’s Ground Two, ineffective assistance of appellate counsel, procedurally defaulted by failing to timely file the 26(B) Application (Report, ECF No. 19, PageID 884-85). Petitioner argued instead that the Fourth District decided his ineffective assistance of appellate counsel claim on the merits, relying on the concluding paragraph of that court’s decision which reads: {¶10} For all of the foregoing reasons, we conclude that appellant's App. R. 26 ( B) application to reopen is without merit. Accordingly, we deny appellant's application to reopen his appeal.

(Opinion, State Court Record, ECF No. 9-5, PageID 531).

The Report rejected Petitioner’s alternative analysis and concluded the language “without merit” was merely conclusory judicial rhetoric used to summarize the results of a proceeding. The Magistrate Judge noted that there was no analysis in the Fourth District’s decision on whether Petitioner had received ineffective assistance of appellate counsel, but only an analysis of whether he met the “good cause” exception to the timeliness requirement. Petitioner objects that the Fourth District’s reliance on the time bar is not unambiguous enough because it includes the “without merit” phrase in its concluding paragraph. The Court disagrees and accepts the Report’s characterization of that language as mere conclusory judicial rhetoric. Moreover, a state court decision upholding a procedural bar can be jointly based on the merits and the state procedural rule and still satisfy the enforcement prong of Maupin. Scott v. Mitchell, 209 F.3d 854 (6th Cir. 2000). Finally, as the Report notes, the question of whether a state court decision is based on a procedural bar is a legal, not a factual question. Combs v. Coyle, 205 F.3d 269, 275 (6th Cir. 2000); Scott v. Mitchell, 209 F.3d 854 (6th Cir. 2000), citing Couch v. Jabe, 951 F.2d 94, 96 (6th Cir. 1991)(per curiam). The Court accepts the Magistrate Judge’s legal conclusion that the Fourth District was enforcing the timelines requirement of App. R. 26(B).

Petitioner also objects that the Fourth District’s decision does not meet the third prong of Maupin analysis by being independent of federal law: Additionally, even if the Appellate Court’s denial was limited to Petitioner’s failure to demonstrate good cause for missing the 90- day deadline, this analysis necessarily required that the Appellate Court interpret and apply federal law. Specifically, in an effort to demonstrate good cause to excuse his delay in filing a timely application pursuant to App. R. 26, Petitioner asserted that he was deprived of the effective assistance of appellate counsel. (Doc. 11, Exhibit 63, PageID#647).

(Objections, ECF No. 19, PageID 890).

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