Simms v. Warden, Grafton Correctional Institution

District Court, S.D. Ohio·Decided August 1, 2023·No. 2:22-cv-00474·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

TIMOTHY SIMMS,

Petitioner, : Case No. 2:22-cv-474

- vs - District Judge Edmund A. Sargus, Jr. Magistrate Judge Michael R. Merz

WARDEN, Grafton Correctional Institution,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case is before the Court on Petitioner’s Objections (ECF No. 25) to the Magistrate Judge’s Report and Recommendations (ECF No. 24) recommending dismissal. District Judge Sargus has recommitted the case for reconsideration in light of the Objections (ECF No. 26). The undersigned had previously recommended dismissing the entire case as barred by the statute of limitations. As to the claims arising from adjudication of Petitioner’s new trial motion, that recommendation has been withdrawn (ECF No. 24, PageID 1519). This Report will analyze those claims on the merits. As to the remaining claims arising at the time of trial, Petitioner has objected to their dismissal on statute of limitations grounds and his objections will be treated here as well. Claims Arising at Trial

Ground One, Two, Three, and that portion of Ground Four that relates to actions that occurred at trial were found to be barred by the statute of limitations because the Petition was filed

more than a year after conclusion of review on direct appeal. Petitioner objected that he had newly- discovered evidence of unconstitutional conduct and he was also exempt from the limitations statute because he was actually innocent. The Supplemental R&R rejected those arguments because Petitioner did not disclose when he had learned of the new evidence and his evidence of actual innocence did not meet the standard of Schlup v. Delo, 513 U.S. 298, 319 (1995)(ECF No. 24).

First Objection Petitioner’s first objection is to the Magistrate Judge’s conclusion that he waived any objection to Respondent’s statute of limitations defense by omitting it from his Reply. The

substance of the objection is that the Magistrate Judge cited cases in which litigants were found to have waived objections to a Magistrate Judge’s report and recommendation by not objecting. The referenced citations are Thomas v. Arn, 474 U.S. 140 (1985); Alspugh v. Mcconnell, 643 F.3d 162, 166 (6th Cir. 2011); Cowherd v. Million, 380 F.3d 909, 912 (6th Cir. 2004); Mattox v. City of Forest Park, 183 F.3d 515, 519 (6th Cir. 1999); Miller v. Currie, 50 F.3d 373, 380 (6th Cir. 1995); United States v. Walters, 638 F.2d 947 (6th Cir. 1981), and they do indeed refer to failure to object to a report and recommendations which is not what happened here. Rather, Respondent pleaded an affirmative defense – expiration of the statute of limitations – in the Return and Petitioner made no response to that defense in his Reply. As Petitioner correctly points out, he was under no duty to file a reply at all, so his failure to respond to the limitations assertion does not forfeit his right to have that question decided on the merits.

Second Objection

Petitioner’s Second Objection is “The Magistrate erred as a matter of law in holding that, because ‘the trial judge did not find the recantation credible’, it cannot constitute sufficient evidence to support an actual innocence gateway claim.” (Objections, ECF No. 25, PageID 1525, citing “R&R 5, PageID 1521”). This objection misstates the holding of the R&R. In discussing Petitioner’s actual innocence claim, the Magistrate Judge merely noted as a matter of fact that the trial judge had found the recantation was not credible. That was not a clearly erroneous factual finding: the trial judge did indeed find the recantation not to be credible: Here, the Court finds the victim's 2014 deposition in which she purports to recant her trial testimony is not credible and would not materially affect the outcome of the trial. At the time of the deposition, the victim was still a minor and was unrepresented by legal counsel. Additionally, present at the deposition was Defendant's mother who at the time was the victim's source of shelter, money, and transportation. Beyond these inherent issues with the deposition, the Court cannot overlook Defendant's own statements to the police as well as the victim's disclosures to CAC and depictions of sex toys at the tender age of nine. All of which point to Defendant's guilt. Accordingly, the Court finds the 2014 deposition of the victim is insufficient to warrant a new trial.

(Decision and Entry, State Court Record, ECF No. 15, Ex. 32, PageID 711-12; emphasis in original). The Magistrate Judge did not find the trial judge’s conclusion on credibility to be dispositive per se, but a factor which this Court could consider in making its own actual innocence finding: “Given the circumstances in which the recantation occurred and the length of time between the purported recantation and its presentation to the courts, this Court is not persuaded the recantation meets the Schlup requirements for proving actual innocence.” (R&R, ECF No. 24,

PageID 1521). There was no error of law in considering the trial judge’s finding of lack of credibility as a factor. Courts considering questions of credibility later in a case’s chronology often give weight to prior findings of lack of credibility by fact finders who have actually observed a particular witness and Petitioner cites no authority to the contrary. Petitioner objects to the bases cited by the Magistrate Judge for rejecting the purported actual innocence showing, to wit, the circumstances in which the recantation occurred and the length of time between recantation and presentation to the courts, by claiming that was all caused by the improper conduct of the prosecutor and the trial judge. [T]he record establishes that any delay in attempting to present the recantation to the trial court is wholly attributable to improper conduct on the part of the prosecutor in intentionally interfering with said presentation and to the collusion in such interference by the trial court by issuing threats of prosecution against the recanting witness prior to even hearing the recantation or the circumstances attendant thereto, which collusion and interference are the subject of issues before this Court that the Magistrate seeks to insulate from federal review.

(Objections, ECF No. 25, PageID 1526-27). Petitioner gives no references at all to where the record supposedly establishes this misconduct, despite Judge Silvain’s Order that record references must be given with PageID numbers (See ECF No. 9). Petitioner specifies some of the conduct of which he complains in his Reply, but gives no record references there either (See ECF No. 17, PageID 1494-85). The facts of the purported recantation are recited by the Ohio Tenth District Court of Appeals in its decision affirming the denial of a new trial: {¶5} On July 18, 2014, E.J., her mother, and paternal grandmother met with T.S. [Petitioner]'s attorney, Tim Pierce, at his office, where E.J. answered questions under oath. Her answers recanted all of the trial testimony that had incriminated her father.

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Simms v. Warden, Grafton Correctional Institution, (S.D. Ohio 2023).

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