Simkins v. Fairbairn

CourtCourt of Appeals for the Tenth Circuit
DecidedDecember 26, 2024
Docket24-1140
StatusUnpublished

This text of Simkins v. Fairbairn (Simkins v. Fairbairn) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Simkins v. Fairbairn, (10th Cir. 2024).

Opinion

Appellate Case: 24-1140 Document: 38 Date Filed: 12/26/2024 Page: 1 FILED United States Court of Appeals Tenth Circuit UNITED STATES COURT OF APPEALS December 26, 2024 FOR THE TENTH CIRCUIT _________________________________ Christopher M. Wolpert Clerk of Court WILLIE J. SIMKINS,

Plaintiff - Appellant,

v. No. 24-1140 (D.C. No. 1:23-CV-02880-LTB-SBP) MARK FAIRBAIRN; ATTORNEY (D. Colo.) GENERAL OF THE STATE OF COLORADO,

Respondents - Appellees. _________________________________

ORDER DENYING CERTIFICATE OF APPEALABILITY * _________________________________

Before PHILLIPS, CARSON, and FEDERICO, Circuit Judges. _________________________________

Willie J. Simkins, a Colorado prisoner proceeding pro se, moves for a

certificate of appealability (COA) to appeal the district court’s denial of his

28 U.S.C. § 2254 petition. We deny a COA and dismiss this matter.

I

In 1999, the State of Colorado charged Simkins with various counts

relating to sexual abuse of a teenage girl. Simkins pleaded guilty to one of

* This order is not binding precedent except under the doctrines of law of

the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 24-1140 Document: 38 Date Filed: 12/26/2024 Page: 2

the charges and was sentenced to lifetime probation upon his discharge

from the Kansas prison system, where he was already serving a sentence

for different crimes. That discharge occurred in 2009. He then violated the

terms of his Colorado probation in 2010 and 2015. The second violation

resulted in revocation of his probation, and the court imposed a prison

sentence of six years to life. Simkins soon began filing a series of

unsuccessful postconviction motions and related appeals in state court, the

most recent of which was resolved in May 2023.

In October 2023, he filed the § 2254 proceeding at issue here. This was

his first § 2254 challenge to the relevant conviction. He claimed that, during

his prosecution, the State never disclosed the report of a medical exam

performed on the victim. That exam showed normal genitals with an intact

hymen. According to Simkins, this was: (1) evidence of actual innocence,

thus excusing him from failing to file a § 2254 petition within the normal

time constraints; and (2) the basis of a claim that the State withheld

exculpatory evidence from him, in violation of Brady v. Maryland, 373 U.S.

83, 87 (1963).

The district court received a pre-answer response from the State and

referred the matter to a magistrate judge. The magistrate judge concluded

that Simkins’s § 2254 petition was indeed untimely according to the various

statutory standards. The magistrate judge further concluded that the exam

2 Appellate Case: 24-1140 Document: 38 Date Filed: 12/26/2024 Page: 3

report did not satisfy the actual-innocence standard, so the untimeliness

could not be excused. The magistrate judge therefore recommended that the

district court deny the petition.

Over Simkins’s objections, the district court adopted the magistrate

judge’s recommendation in full and without further commentary. This

motion for a COA followed.

II

“Unless a circuit justice or judge issues a [COA], an appeal may not

be taken to the court of appeals from . . . the final order in a habeas corpus

proceeding in which the detention complained of arises out of process issued

by a State court . . . .” 28 U.S.C. § 2253(c)(1)(A). A COA requires “a

substantial showing of the denial of a constitutional right.” § 2253(c)(2).

This means Simkins “must demonstrate that reasonable jurists would find

the district court’s assessment of the constitutional claims debatable or

wrong.” Slack v. McDaniel, 529 U.S. 473, 484 (2000). And he must make an

extra showing in this circumstance because the district court resolved his

motion on a procedural basis, namely, untimeliness. So, he must also show

that “jurists of reason would find it debatable whether the district court was

correct in its procedural ruling.” Id.

3 Appellate Case: 24-1140 Document: 38 Date Filed: 12/26/2024 Page: 4

III

A

A prisoner’s federal habeas petition may be timely under various

scenarios. See § 2244(d)(1). The magistrate judge considered and ruled out

three possible scenarios. Simkins does not straightforwardly challenge this

part of the magistrate judge’s analysis. He does, however, describe his

difficulties in obtaining the exam report.

Construing his COA motion liberally because he is pro se, see Hall v.

Scott, 292 F.3d 1264, 1266 (10th Cir. 2002), Simkins may be challenging the

magistrate judge’s conclusion that his habeas petition was not timely under

§ 2244(d)(1)(D). This statutory provision requires a prisoner to bring a

§ 2254 petition within one year of “the date on which the factual predicate

of the claim or claims presented could have been discovered through the

exercise of due diligence.”

Simkins argues that his efforts to demonstrate his innocence began

when he read his arrest affidavit in February 2019. He does not say when

he first obtained the affidavit. In any event, the affidavit was heavily

redacted, but he noticed a reference to a medical exam performed on the

victim. He soon wrote to the public defenders’ office that handled his case,

as well as the clerk of the court where he was convicted. Both denied having

a copy of the report. He obtained the report anyway – he does not explain

4 Appellate Case: 24-1140 Document: 38 Date Filed: 12/26/2024 Page: 5

how or when – but the fact that the public defenders’ office and the state

court did not have a copy was proof, in his view, that the State had never

previously disclosed it.

The magistrate judge noted the Colorado Court of Appeals (CCA) had

evaluated Simkins’s claim based on the exam report and concluded that, at

a minimum, Simkins had been aware of the report’s existence at the time

of his prosecution. The magistrate judge treated this as a factual conclusion

to which a federal habeas court must normally defer. See 28 U.S.C.

§ 2254(e)(1) (“In a [habeas proceeding], a determination of a factual issue

made by a State court shall be presumed to be correct.”). The magistrate

judge therefore determined Simkins had not exercised reasonable diligence

in light of the roughly twenty years between the prosecution and Simkins’s

efforts to overturn his conviction based on the report.

Simkins does not challenge this factual finding (i.e., he knew of the

report’s existence at the time of his prosecution) nor the magistrate judge’s

choice to defer to the CCA’s view of the facts. He also does not explain the

twenty-year delay. Thus, he has not shown that reasonable jurists could

debate the magistrate judge’s conclusion regarding § 2244(d)(1)(D). He

accordingly does not qualify for a COA on this issue.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
House v. Bell
547 U.S. 518 (Supreme Court, 2006)
Raymond J. Hall v. H.N. Sonny Scott
292 F.3d 1264 (Tenth Circuit, 2002)
McQuiggin v. Perkins
133 S. Ct. 1924 (Supreme Court, 2013)
Fontenot v. Crow
4 F.4th 982 (Tenth Circuit, 2021)

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Bluebook (online)
Simkins v. Fairbairn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simkins-v-fairbairn-ca10-2024.