Watkins v. Ballinger

840 S.E.2d 378, 308 Ga. 387
CourtSupreme Court of Georgia
DecidedMarch 13, 2020
DocketS19A1506
StatusPublished
Cited by2 cases

This text of 840 S.E.2d 378 (Watkins v. Ballinger) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Watkins v. Ballinger, 840 S.E.2d 378, 308 Ga. 387 (Ga. 2020).

Opinion

308 Ga. 387 FINAL COPY

S19A1506. WATKINS v. BALLINGER.

BOGGS, Justice.

We granted Joseph Samuel Watkins’ application for a

certificate of probable cause to appeal an order of the Superior Court

of Walker County dismissing Watkins’ second petition for writ of

habeas corpus. The issue presented is whether the habeas court

properly dismissed Watkins’ petition as both untimely and

successive. We conclude that the habeas court erred in dismissing

Watkins’ petition and reverse and remand for further proceedings.

After a 2001 jury trial, Watkins was convicted of felony murder

and related offenses in the shooting death of Isaac Dawkins. This

Court affirmed his convictions in Watkins v. State, 276 Ga. 578 (581

SE2d 23) (2003). Watkins’ first petition for habeas corpus was

denied, and this Court denied his application for a certificate of

probable cause to appeal. See Watkins v. Martin, Case No.

S12H0816 (decided Oct. 15, 2012). Watkins’ federal habeas petition was denied in an unpublished order by the United States District

Court for the Northern District of Georgia, see Watkins v. Crickmar,

Case No. 4:12-cv-00298 (decided Feb. 25, 2013), and the United

States Court of Appeals for the Eleventh Circuit denied his motion

for a certificate of appealability. See Watkins v. Warden, Case No.

13-11292-F (decided June 24, 2013).

In 2017, Watkins filed this second state habeas petition,

raising claims of juror misconduct and concealment by the State of

exculpatory evidence. First, he alleged that a juror, contrary to the

trial court’s explicit instructions not to visit the scene or conduct

timed-drive experiments, conducted just such an experiment.

Second, he alleged that the State failed to reveal exculpatory

evidence to him and allowed a witness to testify that such evidence

did not exist. The warden filed a motion to dismiss the petition as

untimely and successive, asserting that “that motion need[ed] to be

heard and disposed of before any merits . . . consideration can be

done in this matter.”

After a hearing on the motion to dismiss, at which no witnesses were called and the parties agreed to proceed on the record and

argument alone, the habeas court dismissed Watkins’ petition as

both untimely filed under OCGA § 9-14-42 (c) (4) and successive

under OCGA § 9-14-51. In support of its conclusions, the habeas

court determined that “[p]etitioner could reasonably have raised his

current claims in his original petition through speaking with the

juror who allegedly committed misconduct and by obtaining records

through the Open Records Act” to discover the allegedly exculpatory

evidence. We granted Watkins’ application for a certificate of

probable cause to appeal, posing the following question: “Did the

habeas court err in denying petitioner’s juror misconduct claim on

the basis that the claim was untimely and successive?”

OCGA § 9-14-42 (c), enacted in 2004,1 provides a four-year

limitation period on petitions for habeas corpus from felony

convictions, with four potential dates from which the time may begin

to run. See OCGA § 9-14-42 (c) (1)-(4). Paragraph (c) (4) provides

that the limitation period begins at “[t]he date on which the facts

1 See Ga. L. 2004, p. 917, § 1. supporting the claims presented could have been discovered through

the exercise of due diligence.” OCGA § 9-14-42 (c) (4). See Mitchum

v. State, 306 Ga. 878, 885 (1) n.3 (c) (834 SE2d 65) (2019). Other

procedural provisions of the Habeas Corpus Act contain similar

language. For example, OCGA § 9-14-48 (e) provides, with respect

to habeas corpus petitions challenging “convictions had before July

1, 2004,” that if the respondent seeks dismissal on the basis of

prejudicial delay, the petitioner may avoid dismissal by showing “by

a preponderance of the evidence that [the petition] is based on

grounds of which he or she could not have had knowledge by the

exercise of reasonable diligence before the circumstances prejudicial

to the respondent occurred.” See Flint v. State, 288 Ga. 39, 39 n.1

(701 SE2d 174) (2010). Similarly, OCGA § 9-14-51 provides:

All grounds for relief claimed by a petitioner for a writ of habeas corpus shall be raised by a petitioner in his original or amended petition. Any grounds not so raised are waived unless the Constitution of the United States or of this state otherwise requires or unless any judge to whom the petition is assigned, on considering a subsequent petition, finds grounds for relief asserted therein which could not reasonably have been raised in the original or amended petition. See Turpin v. Todd, 268 Ga. 820, 825-826 (2) (a) (493 SE2d 900)

(1997) (looking to analogous federal law and holding that

overcoming procedural bar of OCGA § 9-14-51 requires showing that

factual or legal basis for claim was “not reasonably available” or “not

readily discoverable” to petitioner (punctuation omitted)).

The warden in her brief urges that we not consider cases

construing this similar language by pointing out that those decisions

address procedural provisions of the Habeas Corpus Act not directly

at issue in this appeals, and we therefore should not rely upon those

holdings here. But we cannot interpret OCGA § 9-14-42 (c) (4),

OCGA § 9-14-48 (e), or OCGA § 9-14-51 individually or in a vacuum.

Rather, to determine the meaning of “due diligence,” “reasonably

available,” and “reasonably discoverable” in the context of those

Code sections, we look to the overall context of the statutory habeas

corpus provisions, see Deal v. Coleman, 294 Ga. 170, 172 (1) (a) (751

SE2d 337) (2013) ([W]e must view the statutory text in the context

in which it appears.”). Read together and in context, the Code sections require “due diligence” or “reasonable diligence” in

discovering the underlying facts, and whether those facts were “not

reasonably available” or “could not reasonably have been raised.”

See Black’s Law Dictionary (11th ed. 2019) (defining “due diligence”

in part as, “The diligence reasonably expected from, and ordinarily

exercised by, a person who seeks to satisfy a legal requirement or to

discharge an obligation. — Also termed reasonable diligence;

common diligence.”).

So viewed, consideration of “due diligence,” “reasonable

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Related

Ballinger, Warden v. Watkins
882 S.E.2d 312 (Supreme Court of Georgia, 2022)
Thomas v. Caldwell, Warden
873 S.E.2d 215 (Supreme Court of Georgia, 2022)

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840 S.E.2d 378, 308 Ga. 387, Counsel Stack Legal Research, https://law.counselstack.com/opinion/watkins-v-ballinger-ga-2020.