RICHARDSON v. KAUFFMAN

CourtDistrict Court, E.D. Pennsylvania
DecidedAugust 13, 2021
Docket2:19-cv-02959
StatusUnknown

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

Bluebook
RICHARDSON v. KAUFFMAN, (E.D. Pa. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

OMAR RICHARDSON : Petitioner, : : CIVIL ACTION v. : NO.: 19-2959 : KEVIN KAUFFMAN, et al., : Respondents. :

MEMORANDUM

August 13, 2021

I. INTRODUCTION On March 13, 2001, Omar Richardson (“Petitioner”) was convicted of first-degree murder, possessing instruments of crime, and criminal conspiracy. He was twenty (20) at the time he committed these crimes. Despite his young age, Petitioner was sentenced to life without the possibility of parole. In 2019, Petitioner filed a Petition for Writ of Habeas Corpus (hereinafter “Habeas Petition”), pursuant to 28 U.S.C. § 2254. In a Report and Recommendation (hereinafter “R&R”), the Honorable United States Magistrate Judge Henry S. Perkin recommended that the Habeas Petition be denied with prejudice and dismissed without an evidentiary hearing for being time-barred. Presently before the Court are Petitioner’s objections to Judge Perkin’s R&R. Therein, Petitioner states that his Habeas Petition is timely because he is entitled to statutory or equitable tolling of the limitation period. Alternatively, he asks the Court to consider the merits of an Equal Protection clause violation. Having reviewed all the filings, the Court agrees with Judge Perkin that Petitioner’s Habeas Petition is time-barred. Accordingly, the Court adopts the R&R in its entirety, and Petitioner’s Habeas Petition is denied with prejudice. II. PROCEDURAL HISTORY Petitioner’s underlying Habeas Petition (ECF No. 1) was filed on July 8, 2019. The Court referred the Habeas Petition to Magistrate Judge Perkin on July 16, 2019 (ECF No. 3), and Judge Perkin filed his R&R on November 30, 2020 (ECF No. 13). On May 10, 2021, Petitioner

filed his Objection to the R&R (hereinafter “Objections”). ECF No. 26. Respondents filed a Response to Petitioner’s Objections (hereinafter “Response”) on May 27, 2021 (ECF No. 29), and Petitioner filed a Responsive Reply in support of his Habeas Petition (hereinafter “Reply”) on June 25, 2021 (ECF No. 32). Petitioner’s objections are thus ripe for the Court’s review. III. STANDARD OF REVIEW When R&R objections are filed, the district court must conduct a de novo review of those portions of the R&R to which objections are made. 28 U.S.C. §636(b)(1). If there are no objections to the R&R, or when reviewing those portions of the R&R to which no objections are directed, the court, as a matter of good practice, should “satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.” Fed. R. Civ. P. 72(b), advisory

committee notes; see also Oldrati v. Apfel, 33 F. Supp. 2d 397, 399 (E.D. Pa. 1998) (“In the absence of a timely objection . . . this Court will review [the Magistrate’s] Report and Recommendation for ‘clear error.’”) (internal citations omitted). Petitioner’s objections to the R&R reiterate substantive arguments from his underlying Habeas Petition. Nonetheless, the Court proceeds as if Petitioner properly objected to the outstanding R&R and thus reviews the R&R de novo. IV. DISCUSSION Petitioner objects to the R&R finding that his Habeas Petition is not entitled to statutory or equitable tolling. Objections. 1. He argues that Montgomery v. Louisiana, 577 U.S. 190 (2016)1 made Alleyne v. United States, 570 U.S. 99 (2013)2 retroactive upon collateral review. Habeas Petition 1. Because of this retroactive application, Petitioner argues that a newly recognized constitutional right was created, restarting the one-year statutory period during which he could file a habeas petition, per 28 U.S.C. § 2244(d)(1)(C). Objections 2. Petitioner further

contends that under 28 U.S.C. § 2244(d)(2), the restarted limitations period should have been statutorily tolled while his second PCRA petition was pending. Id. Alternatively, he argues for equitable tolling of the limitations period because he diligently pursued his rights and filed an otherwise timely claim in the wrong forum. Id. at 2-3. These statutory and equitable tolling arguments were correctly denied in Judge Perkin’s R&R. Under 28 U.S.C. § 2244(d)(1)(A), the starting point for counting the one-year statute of limitations is “the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review.” Petitioner’s judgment became final on December 15, 2003. Commonwealth v. Richardson, 833 A.2d 142 (Pa. 2003). Accordingly, the one-year limit to file a federal Petition for Habeas Corpus expired on December 15, 2004.

Petitioner filed his federal Habeas Petition on July 9, 2019, nearly fifteen (15) years after the limitation period expired. Therefore, to be timely, Petitioner’s Habeas Petition would require an alternate start date at which the statutory period began to run, or statutory or equitable tolling would need to apply. A. Alternate Start Date Despite Petitioner’s contentions, an alternate start date based on a newly created constitutional right does not apply. No newly created constitutional right exists because Alleyne

1 In Montgomery, the Supreme Court ruled that the constitutional prohibition on mandatory sentences of life without parole for juvenile offenders announced a new substantive rule that must apply retroactively. 577 U.S. at 212. 2 The Court in Alleyne held that, “[f]acts that increase the mandatory minimum sentence…must be submitted to the jury and found beyond a reasonable doubt.” 570 U.S. at 108. was not made retroactive through Montgomery. This Circuit held in United States v. Reyes, that “[w]hile Alleyne set out a new rule of law, it is not retroactively applicable to cases on collateral review.” 755 F.3d 210, 212 (3d Cir. 2014). Thus, Alleyne is not applicable to Petitioner, and the start time for counting the statutory period under 28 U.S.C. 2244(d)(1)(C) is inapplicable.

Assuming arguendo that 28 U.S.C. 2244(d)(1)(C) did apply though, the one-year period would have begun on January 25, 2016,3 the date on which Montgomery was decided. Petitioner, who did not file until 2019, still would not have filed a timely petition. B. Statutory Tolling Statutory tolling under 28 U.S.C. § 2244(d)(2), which allows tolling for the time during which a “properly filed” application is pending, is also inapplicable. Under Pace v. DiGuglielmo, “time limits, no matter their form, are ‘filing’ conditions.” 544 U.S. 408, 417 (2005). This means that an untimely PCRA is not considered “properly filed.” Id. Petitioner filed his first PCRA petition forty-two (42) days after his judgment became final, tolling the statute with 314 days remaining. On October 11, 2007, discretionary review was denied,

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Related

Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Alleyne v. United States
133 S. Ct. 2151 (Supreme Court, 2013)
Oldrati v. Apfel
33 F. Supp. 2d 397 (E.D. Pennsylvania, 1998)
United States v. Thomas Reyes
755 F.3d 210 (Third Circuit, 2014)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
Montgomery v. Louisiana
577 U.S. 190 (Supreme Court, 2016)
Fahy v. Horn
240 F.3d 239 (Third Circuit, 2001)

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Bluebook (online)
RICHARDSON v. KAUFFMAN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richardson-v-kauffman-paed-2021.