WILLIAM K. SAPP v. CHARLOTTE JENKINS, Warden, Chillicothe Correctional Institute

CourtDistrict Court, S.D. Ohio
DecidedFebruary 2, 2026
Docket2:17-cv-01069
StatusUnknown

This text of WILLIAM K. SAPP v. CHARLOTTE JENKINS, Warden, Chillicothe Correctional Institute (WILLIAM K. SAPP v. CHARLOTTE JENKINS, Warden, Chillicothe Correctional Institute) 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 K. SAPP v. CHARLOTTE JENKINS, Warden, Chillicothe Correctional Institute, (S.D. Ohio 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

WILLIAM K. SAPP,

Petitioner,

v. Case No. 2:17-cv-1069 Chief Judge Sarah D. Morrison CHARLOTTE JENKINS, Warden, Chillicothe Correctional Institute, Magistrate Judge Kimberly A. Jolson Respondent.

OPINION AND ORDER

Petitioner William Sapp, an inmate sentenced to death by the State of Ohio, has pending before this Court a habeas corpus petition pursuant to 28 U.S.C. § 2254. This matter is before the Court on Sapp’s First Motion for Leave to File a Second Amended Petition. (ECF No. 132). Also before the Court are Sapp’s Memorandum in Support of his Motion for Equitable Tolling (ECF No. 140), the Respondent-Warden’s Response in Opposition (ECF No. 141), and Sapp’s Reply (ECF No. 148). For the reasons that follow, Sapp’s Motion for Leave (ECF No. 132) is GRANTED in part and DENIED in part. I. Background Following conclusion of state postconviction appellate proceedings, Sapp’s federal habeas counsel was appointed by Court order on February 5, 2018. (ECF No. 10). On October 31, 2018, Sapp filed his original habeas corpus petition, asserting 18 claims for relief (“Original Petition”). (ECF No. 27). Relevant to the pending Motion for Leave, Claim 10 in the Original Petition alleged that Sapp’s trial counsel was ineffective during all phases of the trial. (ECF No. 27 at PageID# 9417-9426). Respondent answered with a Return of Writ on May 22, 2019. (ECF No. 30). Sapp’s counsel advised the Court during an August 27, 2019, telephone

conference that they received nearly 13,000 records from the Springfield Police Department and intended to file a motion to amend the petition to add a never- before-raised claim alleging that the prosecution failed to disclose material evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963). (ECF No. 34). The Court learned how Sapp received the Springfield Police Department records through a letter provided by Respondent. (ECF No. 59-1). On July 10, 2018, a few months after habeas counsels’ appointment, the Ohio Public Defender made a

public records request on Sapp’s behalf to the Springfield Police Department seeking all documents related to the investigation of the murders of Phree Morrow and Martha Leach. (Id.). Sapp’s habeas counsel advised the Court of when they received the records in a footnote in Sapp’s reply brief: Sapp’s counsel received the Springfield Police Department’s file in September 2018. Counsel began their arduous review of the police file after reading the trial transcripts filed by the Warden on May 30, 2018, the rest of the state court record filed by the Warden on August 31, 2018, and then writing and filing Sapp’s initial habeas petition on October 31, 2018.

(ECF No. 148 at PageID# 32016, fn. 17). The phrasing of the footnote is somewhat unclear, but it appears that Sapp’s counsel did not begin to review the Springfield records received in September of 2018, until after they filed the Original Petition. Based on Sapp’s counsels’ representation at the August 27, 2019, status conference, the Court stayed all of the filing deadlines set forth in its scheduling order (ECF No. 8) and established a briefing schedule for the motions to amend the petition and to stay these proceedings. (ECF No. 34). It appears from the record that the Springfield Police Department provided

more than 12,000 pages of records (ECF No. 67, at PAGEID 25694), and Sapp’s counsel completed review of those records on December 19, 2019 (ECF No. 36, at PAGEID 9541). Following the expansion of the record with the police records, (ECF Nos. 38 and 47), Sapp filed his motions to amend and for stay-and-abeyance on February 25, 2020. Sapp’s proposed amendment (“First Amended Petition”) sought to add Claim 19, alleging that the state violated Brady, and Claim 20, alleging that trial counsel was ineffective at all stages of the proceedings based on information

gleaned from the Springfield Police Department records. (ECF No. 56-1 at 25603- 25612). The Court identified troubling questions about whether Sapp was sufficiently represented in connection with his pursuit of state postconviction relief but also found that there was insufficient information to rule with confidence that Sapp’s proposed amendments were timely. The Court accordingly denied Sapp’s motions to

amend and stay without prejudice to permit Sapp to more fully develop the record. (ECF No. 68). Sapp subsequently requested and received permission to issue a subpoena to the Clark County Prosecutor’s Office. (ECF No. 72, 85). On August 12, 2021, the Clark County Prosecutor’s Office produced 40,100 pages of documents. (ECF No. 98). On September 8, 2022, Sapp’s counsel deposed his postconviction counsel, David Graeff. (ECF No. 133-1). On June 20, 2023, Sapp sought leave to file a second amendment to his habeas petition. (“Second Amended Petition”). (ECF No. 132, 132-1). The Second

Amended Petition expanded upon the Brady and ineffective assistance of counsel claims in the First Amended Petition: Claim 3 (ECF No. 132-1 at PageID# 31123- 31158), which alleges a Brady violation in connection with Morrow and Leach murders, Claim Four (Id. at PageID# 31159-31167, which alleges a Brady violation in connection with the Anderson murder, Claim 5, which alleges a Brady violation in connection with the Pearson attempted murder (Id. at 31167-31172), and Claim 13 (Id. at PageID# 31200-31222), which alleges ineffective assistance of counsel at

all stages of the proceedings. Following Sapp’s request for leave to file his Second Amended Petition, the Court ordered him to brief whether the proposed amendments to the petition are timely. (ECF No. 136). Sapp responded, arguing his amendments were entitled to equitable tolling. (ECF No. 140). Respondent opposes the amendment and disagrees that equitable tolling is appropriate. (ECF No. 141).

II. Analysis A. 28 U.S.C. § 2244 The Antiterrorism and Effective Death Penalty Act of 1996 (PL 104–132, April 24, 1996, 110 Stat 1214) (the “AEDPA”) adopted a statute of limitations for habeas corpus cases running for one year 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.

28 U.S.C. § 2244(d)(1). The provisions in 28 U.S.C. § 2244(d)(1)(B)—(C) plainly do not apply here. Sapp has not overtly invoked Section (D). (ECF No. 140, 148). He makes an argument that his Brady claim is not barred by the statute of limitations because he had no duty to discover the documents that form the basis of his Brady claim. (ECF No. 148 at PageID# 32008-32018). Sapp fails to cite § 2244(d)(1)(D), nor does he argue that the factual predicate could not have been discovered earlier through the exercise of due diligence.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Baggett v. Bullitt
377 U.S. 360 (Supreme Court, 1964)
Lonchar v. Thomas
517 U.S. 314 (Supreme Court, 1996)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Robertson v. Simpson
624 F.3d 781 (Sixth Circuit, 2010)
Ramos-Martinez v. United States
638 F.3d 315 (First Circuit, 2011)
Cowan v. Stovall
645 F.3d 815 (Sixth Circuit, 2011)
Martin v. Associated Truck Lines, Inc.
801 F.2d 246 (Sixth Circuit, 1986)
Doe v. Busby
661 F.3d 1001 (Ninth Circuit, 2011)
ATA v. Scutt
662 F.3d 736 (Sixth Circuit, 2011)
Hall v. Warden, Lebanon Correctional Institution
662 F.3d 745 (Sixth Circuit, 2011)
Matthew Fisher v. Jeanne Roberts
125 F.3d 974 (Sixth Circuit, 1997)
D'Juan Bronaugh v. State of Ohio
235 F.3d 280 (Sixth Circuit, 2000)
Mayle v. Felix
545 U.S. 644 (Supreme Court, 2005)
James Daly v. W. Knipp
585 F. App'x 647 (Ninth Circuit, 2014)
Chivous Robinson v. Joe Easterling
424 F. App'x 439 (Sixth Circuit, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
WILLIAM K. SAPP v. CHARLOTTE JENKINS, Warden, Chillicothe Correctional Institute, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-k-sapp-v-charlotte-jenkins-warden-chillicothe-correctional-ohsd-2026.