TINDALL v. United States

CourtDistrict Court, S.D. Indiana
DecidedJanuary 15, 2025
Docket1:24-cv-00549
StatusUnknown

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

Bluebook
TINDALL v. United States, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

GARY TINDALL, JR., ) ) Petitioner, ) ) v. ) No. 1:24-cv-00549-JMS-TAB ) UNITED STATES OF AMERICA, ) ) Respondent. )

ORDER GRANTING MOTION TO DISMISS

The United States has moved to dismiss Petitioner Gary Tindall, Jr.'s, motion for relief under 28 U.S.C. § 2255. Dkt. 6. For the reasons below, that motion is GRANTED. I. Background On February 8, 2022, the Court entered judgment against Mr. Tindall for drug and gun charges after accepting his guilty plea. United States v. Tindall, No. 1:19-cr-00213-JMS-TAB-1, dkt. 82 (hereinafter "Crim. Dkt."). Mr. Tindall did not appeal the judgment. On March 25, 2024, Mr. Tindall filed a motion to vacate, set aside, or correct sentence under § 2255. Dkt. 1. Regarding the timeliness of the motion, Mr. Tindall states: Defendant argues that the reason the defendant failed to file his appeal and 2255 motion on time is because the defendant's lawyer told defendant that he would file both his appeal within 14 days of sentencing and his 2255 motion. Defendant was under the assumption that his lawyer has been preparing his appeal and 2255 motion. Defendant's lawyer has stopped all contact from the defendant since the sentencing date and that same date was when the defendant's counsel told defendant he was handling the appeal and 2255 motion. The defendant wrote letters and called his counsel may times, leaving messages with no responses, so the defendant has been waiting patiently only to recently find out this counsel could not file his 2255 if counsel wanted to. Defendant was mislead [sic] and lied to by counsel and respectfully asks the Court to accept the defendant's 2255 motion. Had it not been for the defendant's counsel lying and misleading the defendant that he would file the appeal and 2255 motion, the defendant would have filed in a timely manner.

Dkt. 1 at 11. On July 26, 2024, the United States filed a motion to dismiss Mr. Tindall's motion as untimely. Dkt. 6. Mr. Tindall has not responded. II. Analysis The Anti-Terrorism and Effective Death Penalty Act of 1996 establishes a one-year statute of limitations period for § 2255 motions. 28 U.S.C. § 2255(f). The limitations period is triggered by the latest of four events: (1) the date on which the judgment of conviction becomes final; (2) the date on which the impediment to making a motion created by governmental action in violation of the Constitution or laws of the United States is removed, if the movant was prevented from making a motion by such governmental action; (3) the date on which the right asserted was initially recognized by the Supreme Court, if that right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review; or (4) the date on which the facts supporting the claim or claims presented could have been discovered through the exercise of due diligence.

28 U.S.C. § 2255(f). Under § 2255(f)(1), the limitation period begins to run on "the date on which the judgment of conviction [became] final." A judgment of conviction becomes final when the conviction is affirmed on direct review or when the time for perfecting an appeal expires. Clay v. United States, 537 U.S. 522, 527 (2003). A defendant has 14 days after entry of judgment to file a notice of appeal. Fed. R. App. P. 4(b)(1). It is clear that the one-year deadline for Mr. Tindall to file a § 2255 motion expired no later than February 22, 2023—one year plus fourteen days after judgment. Mr. Tindall's motion was filed thirteen months beyond that deadline. Mr. Tindall does not allege that any of the four statutory exceptions for allowing a belated § 2255 filing apply to his case.

Mr. Tindall's motion does suggest that the deadline for filing it might have been equitably tolled. See Boulb v. United States, 818 F.3d 334, 339 (7th Cir. 2016) (citing Holland v. Florida, 560 U.S. 631, 645 (2010)). But equitable tolling is "reserved for extraordinary circumstances far beyond the litigant's control" that prevented him from filing the petition on time. Id. (quoting Socha v. Boughton, 763 F.3d 674, 684 (7th Cir. 2014)). Equitable tolling requires a showing that (1) the petitioner was pursuing his rights diligently; and (2) extraordinary circumstances prevented a timely filing. Holland, 560 U.S. at 649. In Modrowski v. Mote, 322 F.3d 965 (7th Cir. 2003), the Seventh Circuit held that hired counsel's failure to timely file a habeas corpus petition under 28 U.S.C. §§ 2254 and 2241(d) was not grounds for equitably tolling the filing deadline, even if counsel's mental incapacity contributed

to the filing of the petition one day beyond the deadline. First, the Court emphasized "that attorney negligence is not grounds for equitable tolling. The rationale is that attorney negligence is not extraordinary and clients, even if incarcerated, must 'vigilantly oversee,' and ultimately bear responsibility for, their attorneys' actions or failures." Id. at 967-68 (cleaned up). A possible exception to this rule may exist for capital cases, id., which would not apply to Mr. Tindall. Second, the Court declined to "revisit our long-standing determination that petitioners bear ultimate responsibility for their filings, even if that means preparing duplicative petitions: petitioners, 'whether in prison or not, must vigilantly oversee the actions of their attorneys and, if necessary, take matters into their own hands.'" Id. at 968 (quoting Johnson v. McCaughtry, 265 F.3d 559, 566 (7th Cir. 2001)). Third, the Court reaffirmed its rejection of cases from other federal circuits that recognize the possibility of equitable tolling if an attorney has made "affirmative misrepresentations" to a

client. Id. Rather, the law in the Seventh Circuit is that "attorney misconduct, whether labeled negligent, grossly negligent, or willful, is attributable to the client" and does not warrant equitable tolling of filing deadlines in the collateral relief context. Id. The Seventh Circuit has recognized and applied Modrowski's holding to rebut claims of equitable tolling in the context of the one-year filing deadline of § 2255(f). See Lombardo v. United States, 860 F.3d 547, 552 (7th Cir. 2017) (noting that "errors by an attorney acting on a party's behalf do not constitute external obstacles beyond the party's control" and that habeas and § 2255 petitioners do not have a constitutional right to counsel). Applying Modrowski and Lombardo to Mr. Tindall's case, and particularly given his failure to respond to the motion to dismiss, the Court concludes that equitable tolling cannot excuse the

belated filing of his § 2255 motion.

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TINDALL v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tindall-v-united-states-insd-2025.