Rodgers v. Valley

CourtDistrict Court, D. Idaho
DecidedAugust 5, 2022
Docket1:22-cv-00153
StatusUnknown

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

Bluebook
Rodgers v. Valley, (D. Idaho 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

DANIEL EDWARD RODGERS, Case No. 1:22-cv-00153-BLW Petitioner, INITIAL REVIEW ORDER

v.

RANDY VALLEY, Warden ISCI,

Respondent.

Idaho state prisoner Daniel Edward Rogers has filed a Petition for Writ of Habeas Corpus challenging his state court sentence under 28 U.S.C. § 2254. Dkt. 2. Federal habeas corpus relief is available to petitioners who are held in custody under a state court judgment that violates the Constitution, laws, or treaties of the United States. See 28 U.S.C. § 2254(a). The Court is required to review each newly-filed habeas corpus petition to determine whether it should be served, amended, or summarily dismissed. See 28 U.S.C. § 2243. If “it plainly appears from the face of the petition and any attached exhibits that the petitioner is not entitled to relief in the district court,” the petition will be summarily dismissed. Rule 4 of the Rules Governing Section 2254 Cases.

INITIAL REVIEW ORDER - 1 Having reviewed the Petition, the Court concludes that Petitioner may proceed as directed herein below. REVIEW OF THE PETITION

1. Background An Idaho jury convicted Petitioner of committing first degree murder, arising from an incident that occurred on or about June 27, 1987. He was sentenced to a fixed life term without the possibility of parole on August 26, 1988. Dkt. 2, p. 1. The Idaho Supreme Court affirmed his conviction in 1991. See State v. Rodgers, 812 P.2d 1208 (1991).

Petitioner’s post-conviction relief petition was denied, and that decision was affirmed on appeal by the Idaho Supreme Court in 1997. See Rodgers v. State, 932 P.2d 348 (1997). Petitioner now asserts that his fixed life sentence is the equivalent of a thirty-year sentence. He has served thirty years in prison and argues that he is now entitled to release under the statutory scheme in place at the time of his judgment.

2. Discussion Petitioner has not supplied his judgment of conviction. Because the Court’s summary dismissal decision would benefit from a review of the state court record and a statement of the State’s position on Petitioner’s claims, the Court will order Respondent to respond to this Order and file a copy of the judgment of conviction and other state

court records relevant to the narrow issues at hand. The Court identifies the following potential issues.

INITIAL REVIEW ORDER - 2 A. Timeliness and Procedural Default Threshold Issues Petitioner’s federal challenge to his state court criminal judgment is governed by the Anti-terrorism and Effective Death Penalty Act of 1996 (AEDPA). This statute

requires a federal habeas corpus petition to be filed within one year from several triggering dates specified in 28 U.S.C. § 2244(d)(1)(A)-(D). The most common triggering date is the first one, “the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review.” 28 U.S.C. § 2244(d)(1)(A).

The statute also requires that a petitioner first properly exhaust his federal claims in the state court system before bringing them in a federal habeas corpus petition. 28 U.S.C. § 2254(b). That means “fairly presenting the claim,” based on a federal theory, to the highest state court for review in the manner prescribed by state law. See O’Sullivan v. Boerckel, 526 U.S. 838, 845 (1999).

A review of the Petition shows that the factual basis for many of the sentencing claims existed at the time Petitioner was sentenced. For example, he argues that (1) the statute does not define precisely what a sentence of “life imprisonment” means; (2) the sentencing judge failed to make it clear “whether or not Petitioner Rodgers would serve out his life sentence as the remainder of his natural life sentence,” Dkt. 2, p. 10; (3) the

state court “failed to state natural life, remainder of life or until death,” id., and (4) the state statute is unconstitutional because it allows state court judges the discretion to mete

INITIAL REVIEW ORDER - 3 out sentences of indeterminate or determinate life, “prejudicing” those who receive a determinate life sentence.1 Id. The Court sees no reason Petitioner could not have brought these claims on direct

appeal. Perhaps he can show an adequate reason that he did not articulate in his pleadings. If he did not bring these claims on direct appeal, they are considered procedurally defaulted and untimely, as his time period for bringing them in federal court expired in 1997, one year after enactment of AEDPA. Once a federal statute of limitations has expired, it cannot be reinstated or

resurrected by a later-filed state court action. See Ferguson v. Palmateer, 321 F.3d 820, 822 (9th Cir. 2003) (“section 2244(d) does not permit the reinitiation of the limitations period that has ended before the state petition was filed”). On August 6, 2021, many years after Petitioner’s original AEDPA statute of limitations expired, he raised sentencing claims in state court. The claims were dismissed with prejudice by a state

magistrate judge on August 23, 2021. Dkt. 2-1, pp. 36-37. Petitioner’s notice of appeal to

1 Even if timely, this claim appears to be without merit. For example, in Apprendi v. New Jersey, 530 U.S. 466 (2000), the Supreme Court stated:

[N]othing in this history [of common law] suggests that it is impermissible for judges to exercise discretion-taking into consideration various factors relating both to offense and offender-in imposing a judgment within the range prescribed by statute. We have often noted that judges in this country have long exercised discretion of this nature in imposing sentence within statutory limits in the individual case.

Id. at 481 (emphasis in original).

INITIAL REVIEW ORDER - 4 the state district court was dismissed, notwithstanding his assertions that, as a pro se litigant, he could not understand the appeals process. Id., pp.41-43. Petitioner’s appeal to the Idaho Supreme Court was conditionally dismissed for lack of any appealable order or

judgment from the state district court. Id., p. 44. No additional records are attached to the Petition for the Court to review in its analysis. If the state court record shows that the sentencing claims were knowable and available at the time of direct appeal, a later action will not make them into timely claims. To the extent that Petitioner’s new state court action contained claims that were timely—

such as a claim that he is being held past his full-term release date—those claims nevertheless appear to be procedurally defaulted because they were not properly presented in the state court system. B. Options for Disposition of Plaintiff’s Claims Federal habeas corpus law provides for various exceptions to the timeliness and

procedural default rules, and many of those exceptions prolong and expand habeas proceedings because parties are permitted to submit extra-record evidence.

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