William H. Clark v. Warden, Chillicothe Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedDecember 12, 2025
Docket3:25-cv-00002
StatusUnknown

This text of William H. Clark v. Warden, Chillicothe Correctional Institution (William H. Clark v. Warden, Chillicothe Correctional Institution) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
William H. Clark v. Warden, Chillicothe Correctional Institution, (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON

WILLIAM H. CLARK,

Petitioner, : Case No. 3:25-cv-00002

- vs - District Judge Thomas M. Rose Magistrate Judge Michael R. Merz

WARDEN, Chillicothe Correctional Institution,

: Respondent. REPORT AND RECOMMENDATIONS

This is a habeas corpus case, brought pro se by Petitioner William Clark to obtain relief from his conviction in the Darke County Court of Common Pleas on five counts of sexual battery (Petition, ECF No. 1). It is ripe for decision on the Petition, the State Court Record (ECF No. 11, 11-1), Respondent’s Return of Writ (ECF No. 12), and Petitioner’s Traverse (ECF No. 13). The Magistrate Judge reference in the case has recently been transferred to the undersigned to help balance the Magistrate Judge workload in the District (ECF No. 14).

Litigation History

In November, 2014, a Darke County grand jury indicted Petitioner on eleven counts of rape of his minor stepdaughter (Indictment, ECF No. 11, Ex. 1). At arraignment, the trial court entered a plea of not guilty for Petitioner because he had not yet had an opportunity to consult with an attorney. After appointment of counsel and plea negotiations, Petitioner entered a plea of guilty to five counts of sexual battery, pursuant to North Carolina v. Alford, 400 U.S. 25 (1970). Petitioner was sentenced to twenty-five years imprisonment and took no appeal. In August, 2015, Petitioner filed a motion for new trial (Motion, State Court Record, ECF

No. 11, Ex. 6). The Common Pleas Court denied the motion and Petitioner appealed to the Ohio Second District Court of Appeals. That court remanded for reconsideration of the new trial motion as if made under Ohio Revised Code § 2953.21. State v. Clark, 80 N.E.3d 1251 (Ohio App. 2d Dist. Jan 13, 2017) On remand the trial court denied the petition for post-conviction relief (Judgment Entry, State Court Record ECF No. 11, Ex. 17). Petitioner again appealed and the Second District again affirmed. State v. Clark, 2018 WL 4850081 (Ohio App. 2d Dist. Oct. 5, 2018). Petitioner did not appeal to the Ohio Supreme Court, but filed a motion to withdraw his guilty plea in the Common Pleas Court June 15, 2020 (Motion, State Court Record, ECF No. 11, Ex. 25). That court denied

relief and Petitioner again appealed. The Second District again affirmed and Petitioner did not appeal to the Ohio Supreme Court. Instead, on January 5, 2024, Petitioner moved to set aside the judgment (Motion, State Court Record, ECF No. 11, Ex. 36). Judge Hein again denied relief. Id. at Ex. 39. Petitioner again appealed to the Second District and that court again affirmed. State v. Clark, 2024-Ohio- 2646 (Ohio 2d Dist. Jul. 12, 2024). This time Petitioner did appeal to the Ohio Supreme Court, but that court declined to exercise jurisdiction. State v. Clark, 175 Ohio St. 3d 1486 (2024). The Petition was docketed January 2, 2025, but Petitioner’s Declaration asserts it was deposited in the prison mailing system on December 11, 2024 (ECF No. 1, PageID 15). Petitioner pleads one ground for relief: equal protection and due process. As supporting facts, Petitioner states: In lieu of the Ohio Rules of Criminal Procedure which are intended for the just determination of ever criminal proceeding, the lower courts ignored the newly discovered evidence which supported the factual innocence in this case. Moreover, the sentences imposed do not fall within the statutory range as prescribed by the legislature.

(ECF No. 1, PageID 5).

Analysis Respondent asserts Petitioner’s claims are barred by the one-year statute of limitations enacted in 28 U.S.C. § 2244 and by Petitioner’s procedural defaults in presenting his claims to the Ohio state courts (Return of Writ, ECF No. 12).

Statute of Limitations

The relevant statute of limitations, 28 U.S.C. § 2244(d), provides:

(1) A 1-year period of limitation shall apply to an application for a writ of habeas corpus by a person in custody pursuant to the judgment of a State court. The limitation period shall run from the latest of —

(A) the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review;

(B) the date on which the impediment to filing an application created by State action in violation of the Constitution or laws of the United States is removed, if the applicant was prevented from filing by such State action;

(C) the date on which the constitutional right asserted was initially recognized by the Supreme Court, if the right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review; or

(D) the date on which the factual predicate of the claim or claims presented could have been discovered through the exercise of due diligence.

(2) The time during which a properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim is pending shall not be counted toward any period of limitation under this subsection.

Petitioner replies that Respondent has “droned on” about the 1,763 days since judgment when Petitioner has had nothing pending (Traverse, ECF No. 13, PageID 609). Petitioner avers that this should show that the factual predicate had not yet been discovered, thereby presumably claiming the benefit of subsection (d)(1)(D). As to his claim his guilty plea was coerced, the Magistrate Judge disagrees. If Petitioner perceived he had been coerced by counsel into the plea agreement, he certainly knew that at the time he pleaded guilty and it could have been included in his direct appeal. It was not. As to that claim the statute must run from the date the conviction became final, thirty days after judgment was entered, March 15, 2015. If Petitioner is claiming the statute runs from when he discovered the victim’s supposed recantation, the Magistrate Judge also disagrees. The victim’s recantations are not the factual predicate of any claim made in the Petition. Congress did not define “factual predicate” as that term is used in § 2244(d)(1)(D). But courts generally agree that “a factual predicate” consists only of the ‘vital facts’ underlying the claim.” Rivas v. Fischer, 687 F.3d 514, 535 (2d Cir. 2012) (quoting McAleese v. Brennan, 483 F.3d 206, 214 (3d Cir. 2007)); see also Smith v. Meko, 709 F. App'x 341, 344 (6th Cir. 2017); Cole v. Warden, Ga. State Prison, 768 F.3d 1150, 1155 (11th Cir. 2014); Mathena v. United States, 577 F.3d 943, 946 (8th Cir. 2009); Owens v. Boyd, 235 F.3d 356, 359 (7th Cir. 2000); Flanagan v. Johnson, 154 F.3d 196, 199 (5th Cir. 1998). A fact is “vital” if it is required for the habeas petition to overcome sua sponte dismissal. Rivas, 687 F.3d at 535.

Ayers v. Ohio DRC, 113 F.4th 665, 670 (6th Cir. 2024).

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Related

North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
Wainwright v. Sykes
433 U.S. 72 (Supreme Court, 1977)
Herrera v. Collins
506 U.S. 390 (Supreme Court, 1993)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Rivas v. Fischer
687 F.3d 514 (Second Circuit, 2012)
Bob Jay Cole v. Warden, Georgia State Prison
768 F.3d 1150 (Eleventh Circuit, 2014)
James Mathena v. United States
577 F.3d 943 (Eighth Circuit, 2009)
Kurt Smith v. Joseph Meko
709 F. App'x 341 (Sixth Circuit, 2017)

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William H. Clark v. Warden, Chillicothe Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-h-clark-v-warden-chillicothe-correctional-institution-ohsd-2025.