Tarkington v. Harding

CourtDistrict Court, E.D. Oklahoma
DecidedAugust 11, 2022
Docket6:21-cv-00353
StatusUnknown

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

Bluebook
Tarkington v. Harding, (E.D. Okla. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA ADRIAN ADAM TARKINGTON, ) ) Petitioner, ) ) v. ) Case No. CIV 21-353-RAW-KEW ) RANDY HARDING, Warden, ) ) Respondent. ) OPINION AND ORDER This matter is before the Court on Respondent’s motion to dismiss Petitioner’s petition for a writ of habeas corpus, which was filed pursuant to 28 U.S.C. § 2254. Petitioner is a pro se state prisoner in the custody of the Oklahoma Department of Corrections (DOC) who currently is incarcerated at Jim E. Hamilton Correctional Center in Hodgen, Oklahoma. He is attacking his conviction in Okmulgee County District Court Case No. CF-1994-58 for Unlawful Delivery of Narcotics (Dkt. 1 at 1). He raises three grounds for habeas corpus relief: Ground One: Guilty plea Summary of Facts form 13.10 was never filled out completely pursuant to Oklahoma District Court Rule 4.1. Ground Two: There has been a substantial change in the law, pursuant to Title 63, Section 2-401, effective November 1, 2018. Ground Three: The District Court of Okmulgee County was without jurisdiction to prosecute the petitioner in this case because the United States District Court has sole jurisdiction. (Dkt. 1 at 4). Respondent has filed a motion to dismiss, alleging the Court lacks subject matter jurisdiction, because Petitioner is not “in custody,” as required by 28 U.S.C. § 2244(d)(1), and the petition is time-barred by the statute of limitations under 28 U.S.C. § 2244(d)(1)

(Dkt. 8). On February 4, 2022, Petitioner filed a Notice to the Court, complaining of access to the law library and requesting the Court for verification of the DOC policy regarding court-ordered deadlines (Dkt. 10 at 1). He did not, however, demonstrate he had suffered an actual injury from the policy, see Lewis v. Casey, 518 U.S. 343, 350-51 (1996), nor did he show that a denial or delay of access to the court prejudiced him in pursuing litigation, see

Treff v. Galetka, 74 F.3d 191, 194 (10th Cir. 1996). Further, Petitioner did not request an extension of time to respond to Respondent’s motion to dismiss. At the direction of the Court (Dkt. 11), Respondent filed a response to Petitioner’s notice, providing documentation of Petitioner’s access to the facility law library (Dkt. 12).

Petitioner disputed Respondent’s claim that Petitioner had adequate access, however, Petitioner again did not request additional time to file a response to the motion to dismiss (Dkt. 15). Instead, he requested appointment of counsel to represent him in this matter. Id. at 10.

On May 9, 2022, the Court found that Petitioner had adequate access to the prison law library, and he had not demonstrated an actual injury from a limitation to his access (Dkt. 16). He was advised that he could file a proper motion for extension of time, if he needed additional time to file a response to Respondent’s motion to dismiss. Id. The Court also denied Petitioner’s request for appointment of counsel, because he had not complied with

2 Local Civil Rule 7.1(b). Id. The record shows that Petitioner entered a plea of nolo contendere to Unlawful

Delivery of Narcotics, and on December 9, 1994, he was sentenced to five years’ imprisonment, all of which were suspended, with the exception of 11 weekends to be served in the county jail (Dkts. 1 at 1, 9-1 at 2). On April 4, 2016, more than 21 years later, Petitioner filed an application for post-conviction relief in the state district court, arguing he had been deprived of his rights, because the Uniform Summary of Facts Form 13.10 for his

criminal case was not completely filled out (Dkt. 9-2 at 2). The post-conviction application was denied by the district court on April 13, 2016 (Dkt. 9-1 at 3). On July 27, 2016, the Oklahoma Court of Criminal Appeals (OCCA) declined jurisdiction over Petitioner’s post- conviction appeal in Case No. PC- 2016-505, because Petitioner had failed to timely file his

Petition in Error with the OCCA Clerk of Court as required by Rule 5.2(C)(2) of the Rules of the Oklahoma Court of Criminal Appeals, Title 22, Ch. 18, App. (2016) (Dkt. 9-3 at 2). On August 22, 2016, Petitioner filed a second application for post-conviction relief, asserting again that he was deprived of his rights, because the Uniform Summary of Facts

form was not completely filled out (Dkt. 9-4). This application was denied by the district court on August 26, 2016 (Dkt. 9-1 at 3). Petitioner appealed the denial of his application to the OCCA on September 8, 2016, in Case No. PC-2016-818 (Dkt. 9-5 at 2). On November 4, 2016, the OCCA affirmed the denial of the application (Dkt. 9-5 at 3). Petitioner filed a third post-conviction application on November 8, 2019, alleging that

3 a substantial change in the law concerning the sentencing range for possession and distribution of a narcotic entitled him to have his sentence vacated (Dkt. 9-6). The state

district court denied the application on February 22, 2020 (Dkt. 9-1 at 5). On September 28, 2020, Petitioner filed a fourth application for post-conviction relief, asserting the district court lacked authority to prosecute him pursuant to McGirt v. Oklahoma, 591 U.S. __, 140 S. Ct. 2452 (2020) (Dkt. 9-7). Petitioner did not claim Indian status, he instead alleged his crime occurred on the Muskogee Creek Indian Reservation. Id. at 3. The

state district court denied the application on July 2, 2021 (Dkt. 9-1 at 6), and the OCCA affirmed the denial on September 16, 2021, in Case No. PC-2021-781 (Dkt. 9-8 at 2). Respondent alleges that because Petitioner cannot satisfy the “in custody” requirement of 28 U.S.C. § 2254, this Court does not have jurisdiction to consider the habeas petition.

Pursuant to 28 U.S.C. § 2254(a), a federal court “shall entertain an application for a writ of habeas corpus in behalf of a person in custody pursuant to the judgment of a State court only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” In Maleng v. Cook, 490 U.S. 488, 490-91 (1989), the Supreme Court

interpreted the language of § 2254 to require that the habeas petitioner be “‘in custody’ under the conviction or sentence under attack at the time his petition is filed.” To meet the “in custody” requirement, “there must be a significant restraint imposed on one’s liberty.” Gonzales v. Stoker, 575 F.2d 827, 827 (10th Cir. 1978) (citations omitted). The custody requirement is jurisdictional and “encompasses not only individuals subject to

4 immediate physical imprisonment, but also those subject to restraints not shared by the public generally that significantly confine and restrain freedom.” Mays v. Dinwiddie, 580 F.3d

1136, 1139 (10th Cir. 2009). The record shows that when the Okmulgee County District Court denied Petitioner’s first application for post-conviction relief on April 13, 2016, it stated that Petitioner was “not in constructive or actual custody of the State of Oklahoma on these charges and the sentence has been fully discharge[d]” (Dkt 9-9).

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Related

Maleng v. Cook
490 U.S. 488 (Supreme Court, 1989)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
McCormick v. Kline
572 F.3d 841 (Tenth Circuit, 2009)
Mays v. Dinwiddie
580 F.3d 1136 (Tenth Circuit, 2009)
Lackawanna County District Attorney v. Coss
532 U.S. 394 (Supreme Court, 2001)
McGirt v. Oklahoma
591 U. S. 894 (Supreme Court, 2020)
Hall v. Bellmon
935 F.2d 1106 (Tenth Circuit, 1991)

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Bluebook (online)
Tarkington v. Harding, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tarkington-v-harding-oked-2022.