Santiago v. Secretary, Department of Corrections (Polk County)

CourtDistrict Court, M.D. Florida
DecidedApril 23, 2025
Docket8:22-cv-02655
StatusUnknown

This text of Santiago v. Secretary, Department of Corrections (Polk County) (Santiago v. Secretary, Department of Corrections (Polk County)) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Santiago v. Secretary, Department of Corrections (Polk County), (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

JAROL ANTONIO SANTIAGO,

Petitioner,

-vs- Case No. 8:22-cv-2655-CEH-CPT

SECRETARY, DEPARTMENT OF CORRECTIONS,

Respondent. ________________________________/

ORDER

Petitioner, a Florida inmate, initiated this action by petitioning for the writ of habeas corpus under 28 U.S.C. § 2254 (“petition”) (Doc. 1). Respondent moves to dismiss the petition as time barred (Doc. 6), which Petitioner opposes (Doc. 7). Upon consideration, the petition will be denied as time barred. Procedural Background A jury found Petitioner guilty of first-degree murder and tampering with evidence (Doc. 6-2, Ex. 2).1 He was sentenced to life in prison on the murder conviction and to 5 years in prison on the tampering conviction (Id., Ex. 3). His convictions and sentences were affirmed on appeal on February 25, 2015 (Id., Ex. 6).

1 Unless otherwise indicated, for purposes of reference to pleadings and exhibits, the Court will cite the document page numbers assigned by the Court’s electronic docketing system. 1 On February 25, 2016, Petitioner filed a petition for a writ of habeas corpus alleging ineffective assistance of appellate counsel (Id., Ex. 8). The petition was denied on March 30, 2016 (Id., Ex. 9). On June 21, 2016, Petitioner filed a motion for post-conviction relief under Rule 3.850, Fla.R.Crim.P. (Id., Ex. 10). The Rule 3.850 motion was denied (Id., Ex. 11). The

denial was affirmed on appeal (id., Ex. 14), and the appellate court mandate issued on July 21, 2021 (Id., Ex. 15). On July 6, 2021, Petitioner filed a motion for jail credit (Id., Ex. 16). The motion was dismissed as untimely (Id., Ex. 17). Petitioner did not appeal.

On July 20, 2021, Petitioner filed a motion to correct an illegal sentence under Rule 3.800, Fla.R.Crim.P. (Id., Ex. 18). Because the motion challenged Petitioner’s murder conviction, the state post-conviction court construed it as a motion under Rule 3.850 and dismissed it on November 1, 2021, as “facially insufficient, untimely, and successive.” (Id., Ex. 19). On April 27, 2022, Petitioner filed a petition for a belated appeal of the order

dismissing his construed Rule 3.850 motion (Id., Ex. 21). The petition was granted on July 8, 2022 (Id., Ex. 22). The denial of the construed Rule 3.850 motion was affirmed on appeal (id., Ex. 24), and the appellate court mandate issued on October 10, 2022 (Id., Ex. 25). Petitioner filed his federal habeas petition on November 14, 2022 (Doc. 1 at 1).2

2 A pleading is considered filed by a prisoner on the date it was delivered to prison authorities 2 Discussion Respondent moves to dismiss the petition as time barred (Doc. 6). The Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”) establishes a one- year statute of limitations within which a state prisoner may file a federal habeas petition. 28 U.S.C. § 2244(d)(1). Lawrence v. Florida, 549 U.S. 327, 331 (2007). Section 2244(d)(1)

provides: (d)(1) A 1–year period of limitation shall apply to an application for a writ of habeas corpus by a person in custody pursuant to the judgment of a State court. The limitation period shall run from the latest of—

(A) the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review;

(B) the date on which the impediment to filing an application created by State action in violation of the Constitution or laws of the United States is removed, if the applicant was prevented from filing by such State action;

(C) the date on which the constitutional right asserted was initially recognized by the Supreme Court, if the right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review; or

(D) the date on which the factual predicate of the claim or claims presented could have been discovered through the exercise of due diligence.

For purposes of the AEDPA, the relevant one-year limitations period applicable here runs from “the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review.” § 2244(d)(1)(A). And under

for mailing. See Garvey v. Vaughn, 993 F.2d 776, 783 (11th Cir. 1993) (stating that “the date of filing shall be that of delivery to prison officials of a complaint or other papers destined for district court for the purpose of ascertaining timeliness”). 3 28 U.S.C. § 2244(d)(2), “[t]he time during which a properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim is pending shall not be counted toward any period of limitation under this subsection.” Petitioner’s judgment was affirmed on February 25, 2015, so his convictions became final ninety days later, on May 26, 2015. See Sup.Ct.R. 13; Nix v. Sec’y, Fla. Dep’t

of Corr., 393 F.3d 1235, 1236-37 (11th Cir. 2004) (holding that a petitioner’s conviction became final, for federal habeas purposes, after the expiration of the 90-day period in which he could have sought certiorari review in the United States Supreme Court). Thus, the AEDPA statute of limitations started the next day, May 27, 2015. The limitations period ran for 274 days before it was tolled by Petitioner’s February

25, 2016 petition alleging ineffective assistance of appellate counsel. The period remained tolled until the petition was denied on March 30, 2016. Another 83 days of the period elapsed before it was tolled again by Petitioner’s June 21, 2016 Rule 3.850 motion. The period remained tolled until July 21, 2021, when the mandate was issued on appeal from the denial of the motion.

Petitioner filed his motion for jail credit on July 6, 2021, and his Rule 3.800 motion to correct illegal sentence (construed as a Rule 3.850 motion) on July 20, 2021. But neither motion tolled the limitations period because neither was “properly filed,” since both were dismissed as untimely. See Jones v. Sec’y, Fla. Dep’t of Corr., 906 F.3d 1339, 1342 (11th Cir. 2018) (“In Pace v. DiGuglielmo, 544 U.S. 408, 125 S.Ct. 1807, 161 L.Ed.2d 669 (2005), the

4 United States Supreme Court expressly held that a state court motion for post-conviction relief cannot be considered ‘properly filed’ for tolling under Section 2244(d)(2) if the motion was untimely under state law.”). Thus, the limitations period elapsed on July 30, 2021.3 Accordingly, Petitioner’s federal habeas petition, filed on November 22, 2022, is untimely.

In his reply, Petitioner appears to contend that he is entitled to equitable tolling of the limitations period (Doc. 7). The AEDPA’s statute of limitations is subject to equitable tolling. Holland v. Florida, 560 U.S. 631 (2010). “[A] petitioner is entitled to equitable tolling only if he shows (1) that he has been pursuing his rights diligently, and (2) that some extraordinary circumstance stood in his way and prevented timely filing.” Id., at

649.

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Related

Nix v. Secretary for the Department of Corrections
393 F.3d 1235 (Eleventh Circuit, 2004)
Downs v. McNeil
520 F.3d 1311 (Eleventh Circuit, 2008)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Lawrence v. Florida
549 U.S. 327 (Supreme Court, 2007)
McQuiggin v. Perkins
133 S. Ct. 1924 (Supreme Court, 2013)
Holland v. Florida
177 L. Ed. 2d 130 (Supreme Court, 2010)
Garvey v. Vaughn
993 F.2d 776 (Eleventh Circuit, 1993)

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Santiago v. Secretary, Department of Corrections (Polk County), Counsel Stack Legal Research, https://law.counselstack.com/opinion/santiago-v-secretary-department-of-corrections-polk-county-flmd-2025.