Ruiz v. Superintendent of SCI-Forest

CourtDistrict Court, M.D. Pennsylvania
DecidedAugust 11, 2025
Docket3:25-cv-00499
StatusUnknown

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Ruiz v. Superintendent of SCI-Forest, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

JOSE RUIZ, :

Petitioner : CIVIL ACTION NO. 3:25-cv-499

v. : (JUDGE MANNION)

SUPERINTENDENT OF SCI : FOREST, et al., : Respondents

MEMORANDUM

Presently before the Court is pro se Petitioner Jose Ruiz (“Ruiz”)’s petition for a writ of habeas corpus under 28 U.S.C. §2254. For the reasons set forth below, the Court will dismiss the petition.1 I. BACKGROUND Ruiz, who is currently incarcerated at Pennsylvania State Correctional Institution Forest, commenced this action by filing his Section 2254 petition on March 11, 2025.2 (Doc. 1.) In his petition, Ruiz indicates that he is

1 Ruiz also filed an application for leave to proceed in forma pauperis (“IFP Application”) with his petition. (Doc. 2.) However, a day after filing the application, Ruiz remitted the filing fee. See (Unnumbered Docket Entry After Doc. 3). Therefore, the Court will deny the IFP Application as moot.

2 The federal “prisoner mailbox rule” provides that a pro se prisoner’s submission is deemed filed “at the time [the prisoner] delivered it to the prison authorities for forwarding to the court clerk.” Houston v. Lack, 487 U.S. 266, (footnote continued on next page) challenging his criminal convictions and sentence from two (2) criminal cases in the York County Court of Common Pleas, Nos. CP-67-CR-7560-2006

(“No. 7560-2006”) and CP-67-CR-1095-2008 (“No. 1095-2008”). (Id. at 1.) The Court will first discuss Ruiz’s prior state and federal proceedings pertaining to these cases before briefly summarizing his claims in his habeas

petition filed in this case. A. Ruiz’s Underlying Criminal Convictions and Sentence The facts and procedural histories of the criminal cases Ruiz identifies as those he is challenging in his Section 2254 petition—Nos. 7560-2006 and

1095-2008—have been previously described as follows: [No. 7560-2006] On September 19, 2007, after a jury trial, [Ruiz] was found guilty of one count each of rape of a child, involuntary deviate sexual intercourse with a child, aggravated indecent assault of a child, and two counts each of unlawful contact with a minor, indecent assault, and corruption of minors.

On June 20, 2008, the trial court sentenced Ruiz to a term of incarceration of not less than sixteen nor more than thirty-two years[’] incarceration.

On September 24, 2008, Ruiz filed a Notice of Appeal with the Pennsylvania Superior Court.

276 (1988). Here, Ruiz included a declaration with his petition in which he indicates that he placed his petition in the prison mail system on March 11, 2025. (Doc. 1 at 14.) As such, the Court uses March 11, 2025 as the petition’s filing date even though the Clerk of Court did not docket it until March 19, 2025. On September 2, 2009, the Pennsylvania Superior Court affirmed [Ruiz]’s judgment of sentence.

Ruiz did not file for allowance of appeal [with] the Pennsylvania Supreme Court.

[No. 1095-2008]

On July 15, 2009, after a jury trial, [Ruiz] was found guilty of three counts each of rape of a child, involuntary deviate sexual intercourse with a child, and unlawful contact with a minor.

On October 26, 2009, the trial court sentenced Ruiz to a term of incarceration of not less than thirty nor more than sixty years[’] incarceration.

On January 28, 2010, Ruiz filed a Notice of Appeal with the Pennsylvania Superior Court.

On December 7, 2010, the Pennsylvania Superior Court affirmed [Ruiz]'s judgment of sentence.

On June 7, 2011, the Pennsylvania Supreme Court denied Ruiz’s petition for allowance of appeal.

On June 13, 2012, Ruiz filed his first pro se petition under Pennsylvania’s Post Conviction Relief Act, 42 Pa. C.S.[] §§9541[–46] (“PCRA”), collaterally attacking his convictions in [Nos. 7560-2006 and 1095-2008]. Counsel was appointed, but rather than filing an amended PCRA petition, Ruiz’s counsel filed a . . . petition seeking permission to withdraw. On November 5, 2012, the Court granted counsel’s request to withdraw. On December 10, 2012, the PCRA [court] entered an order denying Ruiz’s PCRA petition.

On September 13, 2013, Ruiz filed a second pro se PCRA petition, again collaterally attacking his convictions in cases [Nos. 7560-2006 and 1095-2008]. On September 30, 2013, the PCRA Court provided Ruiz with a notice of its intent to dismiss the PCRA petition pursuant to Pa. R. Crim. P. 907(1). Ruiz did not respond to the Rule 907 notice. Instead, on October 16, 2013, he filed a notice of appeal from the order entered September 30, 2013 and a statement of errors complained of on appeal. On October 25, 2013, the PCRA court entered its order dismissing Ruiz’s petition. By Memorandum Opinion dated September 30, 2014, the Pennsylvania Superior Court affirmed the PCRA court’s dismissal of Ruiz’s PCRA petition as untimely.

On October 10, 2014, Ruiz filed a petition for allowance of appeal to the Pennsylvania Supreme Court from the Superior Court’s September 30, 2014 Memorandum Opinion, which was denied on December 10, 2014.

Ruiz v. Harry, No. 15-cv-99, 2016 WL 438984, at *1–2 (M.D. Pa. Feb 3, 2016). B. Ruiz’s Prior Federal Habeas Proceedings On January 16, 2015, Ruiz filed a Section 2254 habeas petition challenging his convictions and sentence in Nos. 7560-2006 and 1095-2008, which was assigned to the Honorable William J. Nealon, who is now deceased. See Ruiz v. Harry, et al., No. 15-cv-99 (M.D. Pa.), ECF No. 1. Approximately two (2) months later, Judge Nealon issued a notice to Ruiz indicating that he could either (1) have his petition ruled on as filed, that is, as a Section 2254 petition, but lose his ability to file a second or successive petition, absent certification by the court of appeals; or (2) withdraw his petition and file one all-inclusive Section 2254 petition within the one (1)-year statutory period prescribed by the Antiterrorism Effective Death Penalty Act (“AEDPA”). See id., ECF No. 2. On March 16, 2015, Ruiz returned the notice of election, indicating that he wanted to proceed with his Section 2254 petition as filed. See id., ECF No. 3.

On April 7, 2015, Respondent filed a motion to dismiss Ruiz’s Section 2254 petition as untimely. See id., ECF No. 5. Ruiz never filed a brief in opposition to this motion. See Ruiz, 2016 WL 438984, at *2. On February 3,

2016, Judge Nealon issued a Memorandum and Order dismissing Ruiz’s Section 2254 habeas petition as untimely. See id. at *4; Ruiz v. Harry, et al., No. 15-cv-99 (M.D. Pa.), ECF Nos. 14, 15. Ruiz filed a notice of appeal from Judge Nealon’s dismissal of his

Section 2254 petition to the Third Circuit Court of Appeals. See Ruiz v. Harry, et al., No. 15-cv-99 (M.D. Pa.), ECF No. 16. On May 13, 2016, the Third Circuit denied Ruiz’s request for a certificate of appealability. See id., ECF

No. 20. Ruiz filed a petition for a writ of certiorari with the United States Supreme Court, which the Supreme Court denied on October 3, 2016. See Ruiz v. Harry, No. 16-5666 (S. Ct.). C. Ruiz’s Claims in His Instant Section 2254 Petition

In his Section 2254 petition, Ruiz asserts four (4) claims. First, Ruiz argues that the “government” and “prosecution” interfered with his ability to file a timely petition because they “failed to notify [him] of his [d]ue [p]rocess

rights to immigration [sic] judge order of removal.” (Doc. 1 at 5.) Ruiz argues that “the government’s failure to give [him] a due process hearing amounts to government interference and [therefore] meets the timeliness exception.”

(Id.) Second, Ruiz contends that his sentence violates the Eighth Amendment to the United States Constitution. (Id. at 6.) He argues that his

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