Robinson v. SDCC Warden Hutchings

CourtDistrict Court, D. Nevada
DecidedMarch 22, 2024
Docket2:21-cv-01989
StatusUnknown

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

Bluebook
Robinson v. SDCC Warden Hutchings, (D. Nev. 2024).

Opinion

3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 ERIC DEON ROBINSON, Case No. 2:21-cv-01989-RFB-DJA

6 Petitioner, v. ORDER 7 GABRIELA NAJERA, et al., 8 Respondents. 9 10 This habeas action is brought by Petitioner Eric Deon Robinson under 22 U.S.C. § 2254. 11 Respondents filed a Motion to Dismiss (ECF No. 26) Grounds Three and Four of the first 12 amended petition as untimely. Also before the Court is Respondents’ Motion for Leave to File 13 Exhibits Under Seal (ECF No. 24). For the reasons discussed below, the Court grants 14 Respondents’ motion to dismiss, in part, finding Ground Three untimely and grants their motion 15 for leave to file exhibits under seal. 16 I. BACKGROUND 17 Robinson challenges a conviction and sentence imposed by the Eighth Judicial District 18 Court for Clark County. In June 2017, the state court entered a judgment of conviction for 19 conspiracy to commit kidnapping, first degree kidnapping with use of a deadly weapon, coercion 20 with use of a deadly weapon, two counts of first-degree kidnapping with use of a deadly weapon 21 resulting in substantial bodily harm, first degree murder with use of a deadly weapon, and 22 attempted murder with use of a deadly weapon. The Nevada Supreme Court affirmed the 23 conviction. In June 2020, Robinson filed a state petition for writ of habeas corpus. The state 24 court denied post-conviction relief and the Nevada Supreme Court affirmed the denial of relief. 25 On October 29, 2021, Robinson initiated this federal habeas corpus proceeding pro se. 26 ECF No. 1. Following appointment of counsel, on May 23, 2023, Robinson filed a first amended 27 habeas petition. ECF Nos. 14, 20. Respondents argue that because the first amended petition is 28 untimely, Grounds Three and Four should be dismissed because the claims do not relate back to 1 Robinson’s earlier timely filed petition. ECF No. 26 at 4-6. 2 II. DISCUSSION 3 a. Relation Back 4 A new claim in an amended petition that is filed after the expiration of the Antiterrorism 5 and Effective Death Penalty Act (“AEDPA”) one-year limitation period will be timely only if the 6 new claim relates back to a claim in a timely-filed pleading under Rule 15(c) of the Federal 7 Rules of Civil Procedure. Under Rule 15, an untimely amendment properly “relates back to the 8 date of the original pleading” as long as it arises out of the same “conduct, transaction, or 9 occurrence.” Fed. R. Civ. P. 15(c). For habeas petitions, “relation back depends on the existence 10 of a common core of operative facts uniting the original and newly asserted claims.” Mayle v. 11 Felix, 545 U.S. 644, 659 (2005). 12 New claims in an amended habeas petition do not arise out of “the same conduct, 13 transaction or occurrence” as prior claims merely because they challenge the same trial, 14 conviction, or sentence. Mayle, 545 U.S. at 661; Hebner v. McGrath, 543 F.3d 1133, 1134 (9th 15 Cir. 2008) (“It is not enough that the new argument pertains to the same trial, conviction, or 16 sentence.”). Rather, to properly relate back, a new claim must arise from the same collection of 17 facts alleged in the earlier petition. Mayle, 545 U.S. at 661; Schneider v. McDaniel, 674 F.3d 18 1144, 1151 (9th Cir. 2012) (holding that one shared fact in two divergent legal theories was “not 19 sufficient to conclude that they arise out of a common core of operative facts”). An amended 20 habeas petition “does not relate back (and thereby escape AEDPA’s one-year time limit) when it 21 asserts a new ground for relief supported by facts that differ in both time and type” from those 22 alleged in the timely petition. Mayle, 545 U.S. at 650. 23 Respondents contend that Grounds Three and Four are untimely because Robinson did 24 not raise these claims in his original pro se petition. ECF No. 26 at 6. Robinson asserts that his 25 original petition raises ineffective assistance of counsel claims and both claims were discussed in 26 the Nevada Court of Appeals’ decision attached to his original petition. ECF No. 27 at 3. 27 Robinson relies on the Ninth Circuit’s decision in Ross v. Williams, 950 F.3d 1160 (9th Cir. 28 2020), which held that a state appellate court’s order, attached to a timely petition, was 1 incorporated by reference for the relation-back purposes pursuant to Civil Rules 10(c), 2 15(c)(1)(B), and 81(a)(4), 28 U.S.C. § 2242, and Habeas Rule 12. 950 F.3d at 1167. “‘For all 3 purposes,’ including relation back, the original petition consists of the petition itself and any 4 ‘written instruments’ that are exhibits to the petition.” Ross, 950 F.3d at 1167 (quoting Fed. R. 5 Civ. P. 10(c) (internal bracketing omitted)). “Like a brief, a court decision is a written 6 instrument.” Ross, 950 F.3d at 1167 (citing Dye v. Hofbauer, 546 U.S. 1, 4 (2005)). 7 Ross instructs courts to “follow two steps to determine whether an amended petition 8 relates back to an original petition that relied on an appended written instrument to help set forth 9 the facts on which it based its claims”: (1) courts “determine what claims the amended petition 10 alleges and what core facts underlie those claims,” and (2) “for each claim in the amended 11 petition,” courts examine “the body of the original petition and its exhibits” to see whether the 12 pleading set out or attempted to set out “a corresponding factual episode” or “whether the claim 13 is instead supported by facts that differ in both time and type” from those set forth in the original 14 petition. 950 F.3d at 1167 (quoting Fed. R. Civ. P. 15(c)(1)(B); Mayle, 545 U.S. at 650) 15 (internal quotation marks omitted). 16 “The central question under this framework is whether the amended and original petitions 17 share a common core of operative facts, as those facts are laid out in the amended petition and 18 ‘attempted to be set out’ in the original petition.” Ross, 950 F.3d at 1168. “Relation back may be 19 appropriate if the later pleading merely corrects technical deficiencies or expands or modifies the 20 facts alleged in the earlier pleading, restates the original claim with greater particularity, or 21 amplifies the details of the transaction alleged in the preceding pleading.” Ross, 950 F.3d at 1168 22 (internal brackets, quotation marks, and citation omitted) (citing 6A Charles Alan Wright & 23 Arthur R. Miller, Federal Practice and Procedure § 1497 (3d ed. 2019) (internal brackets and 24 quotation marks omitted)). 25 b. Ground Three does not relate back to the original petition. 26 In Ground Three of his first amended petition, Robinson alleges that the state trial court 27 erred because it did not find that trial counsel rendered ineffective assistance for failure to 28 recognize statements regarding the stolen gun, money, and drugs were inadmissible as res gestae 1 evidence. ECF No. 20 at 16-19. Robinson asserts that his pro se allegations referencing 2 ineffective assistance of counsel in addition to the Nevada Court of Appeals’ decision discussing 3 ineffective assistance of counsel attached to his original petition establish a common core of 4 operative facts sufficient to meet the relation back doctrine. Respondents argue that Robinson’s 5 allegations regarding res gestae do not appear anywhere in his original petition.

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Related

Vicor Corp. v. Vigilant Insurance
674 F.3d 1 (First Circuit, 2012)
Mayle v. Felix
545 U.S. 644 (Supreme Court, 2005)
Hebner v. McGrath
543 F.3d 1133 (Ninth Circuit, 2008)
Dye v. Hofbauer
546 U.S. 1 (Supreme Court, 2005)
Kamakana v. City and County of Honolulu
447 F.3d 1172 (Ninth Circuit, 2006)
Ronald Ross v. Williams
950 F.3d 1160 (Ninth Circuit, 2020)

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Robinson v. SDCC Warden Hutchings, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robinson-v-sdcc-warden-hutchings-nvd-2024.