William P. Castillo v. William Reubart, (DEATH PENALTY)

CourtDistrict Court, D. Nevada
DecidedSeptember 20, 2022
Docket2:04-cv-00868
StatusUnknown

This text of William P. Castillo v. William Reubart, (DEATH PENALTY) (William P. Castillo v. William Reubart, (DEATH PENALTY)) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
William P. Castillo v. William Reubart, (DEATH PENALTY), (D. Nev. 2022).

Opinion

2 UNITED STATES DISTRICT COURT

3 DISTRICT OF NEVADA

4 * * *

5 WILLIAM P. CASTILLO, Case No. 2:04-cv-00868-RCJ-EJY

6 Petitioner, ORDER 7 v.

8 WILLIAM REUBART, et al., 9 Respondents. 10

11 12 13 I. Summary 14 In this capital habeas corpus action, on January 14, 2019, this Court denied 15 William P. Castillo’s habeas petition and granted a certificate of appealability, and 16 judgment was entered accordingly (ECF Nos. 231, 232). On September 16, 2019, this 17 Court partially granted Castillo’s motion to alter or amend judgment and expanded the 18 certificate of appealability (ECF Nos. 246, 247). Castillo appealed (ECF Nos. 234, 248). 19 On January 13, 2021, the Ninth Circuit Court of Appeals granted Castillo’s 20 unopposed motion for a stay and limited remand and remanded the case to this Court. 21 See Order of Court of Appeals filed January 13, 2021 (ECF No. 251). The court of 22 appeals ordered:

23 On limited remand, the District Court will reconsider its relation back order, and its disposition of those claims, in light of intervening law. See Dist Ct 24 3/02/2016 Order (Dist Ct DE 184); see Ross v. Williams, 950 F.3d 1160 (9th Cir. 2020) (en banc). 25 26 Id. at 1. 27 Therefore, on January 25, 2021, this Court set a schedule for the parties to file 1 The Court ordered that its review of this case on this limited remand would be limited to 2 the issue identified by the court of appeals: the effect of intervening law on this Court’s 3 rulings in the order entered March 2, 2016 (ECF No. 184) regarding whether certain 4 claims in Castillo’s second amended habeas petition relate back to his original petition 5 for purposes of the application of the statute of limitations. Id. 6 Castillo filed his opening brief on remand on May 25, 2021 (ECF No. 255). 7 Respondents filed their answering brief on remand on June 23, 2022 (ECF No. 269). 8 Castillo did not file a reply brief. See Order entered January 25, 2021 (ECF No. 252) (30 9 days to file reply brief). 10 In his opening brief on remand, Castillo argues that the Court should reconsider 11 its ruling that Claims 1(II)(A), 1(II)(B), 3(I)(B), 3(I)(C), 3(II)(B), 4, 5, 17 and 19 of his 12 second amended petition do not relate back to his original petition for purposes of 13 application of the statute of limitations, and he argues that the Court should reconsider 14 its ruling that Claims 1(II)(A), 1(II)(B), 3(I)(C), 3(II)(B), 4 and 5 are barred under the 15 procedural default doctrine. See Opening Brief on Remand (ECF No. 255). 16 The Court determines that Ross v. Williams, 950 F.3d 1160 (9th Cir.) (en banc), 17 cert. denied sub nom. Daniels v. Ross, 141 S. Ct. 840 (2020), does not change its prior 18 conclusions that none of Claims 1(II)(A), 1(II)(B), 3(I)(B), 3(I)(C), 3(II)(B), 4, 5, or 17 19 relates back, or its conclusion regarding the extent to which the cumulative error claim 20 in Claim 19 is barred by the statute of limitations, and the Court declines to reconsider 21 its rulings regarding the procedural default of Claims 1(II)(A), 1(II)(B), 3(I)(C), 3(II)(B), 4 22 and 5. 23 II. Discussion

24 A. Relation Back - Legal Principles - Ross 25 In the March 2, 2016, order resolving Respondents’ motion to dismiss, the Court 26 explained the background of the statute of limitations issue, and the reason the issue 27 arises, as follows: 1

2 Under the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), there is a one-year statute of limitations applicable to federal 3 habeas corpus petitions. The statute provides:

4 (d)(1) A 1-year period of limitation shall apply to an application for a writ of habeas corpus by a person in 5 custody pursuant to the judgment of a State court. The limitation period shall run from the latest of – 6 (A) the date on which the judgment became 7 final by the conclusion of direct review or the expiration of the time for seeking such review; 8 (B) the date on which the impediment to filing 9 an application created by State action in violation of the Constitution or laws of the 10 United States is removed, if the applicant was prevented from filing by such State action; 11 (C) the date on which the constitutional right 12 asserted was initially recognized by the Supreme Court, if the right has been newly 13 recognized by the Supreme Court and made retroactively applicable to cases on collateral 14 review; or

15 (D) the date on which the factual predicate of the claim or claims presented could have been 16 discovered through the exercise of due diligence. 17 28 U.S.C. § 2244(d)(1)(A-D). 18 The petitioner is entitled to statutory tolling of the limitations period 19 while a “properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim is 20 pending.” 28 U.S.C. § 2244(d)(2).

21 * * *

22 Castillo’s conviction became final on March 22, 1999, when the United States Supreme Court denied his petition for a writ of certiorari. 23 See Castillo v. Nevada, 526 U.S. 1031 (1999); Letter Regarding Denial of Petition for Writ of Certiorari, Respondents’ Exhibit 129. The one-year 24 limitations period for Castillo’s federal habeas petition began running on that date. 25 Castillo filed his first state habeas petition eleven days later, on 26 April 2, 1999. There is no question that Castillo’s first state habeas action was “properly filed,” such that it tolled the limitations period, under 27 28 U.S.C. § 2244(d)(2), after only eleven days ran against the limitations remittitur on October 27, 2004, after affirming the denial of relief in 1 Castillo’s action. See Remittitur, Respondents’ Exhibit 211. The running of the limitations period resumed on that date. 2 Therefore, without any equitable tolling, the one-year limitations 3 period ran out 354 days later, on October 16, 2005.

4 Castillo mailed his original pro se habeas petition to this court for filing on June 22, 2004, before the Nevada Supreme Court issued its 5 remittitur, concluding Castillo’s first state habeas action. See Petition for Writ of Habeas Corpus (ECF No. 1). Under the “mailbox rule,” the court 6 considers the petition to have been filed on that date. See Houston v. Lack, 487 U.S. 266, 276 (1988); Rule 3(d) of the Rules Governing Section 7 2254 Cases in the United States District Courts. Castillo’s original petition in this action was unquestionably timely-filed. 8 However, without equitable tolling, Castillo’s first amended petition, 9 and his second amended petition, were untimely. The pendency of Castillo’s federal habeas action did not toll the limitations period. See 10 Duncan v. Walker, 533 U.S. 167, 181–82 (2001) (no tolling for the pendency of a federal habeas petition). Castillo’s first amended petition 11 was filed on December 15, 2008, which was 1156 days—3 years, 1 month, and 29 days—after the limitations period expired. See First 12 Amended Petition (ECF No. 70). Castillo’s second amended petition was filed on May 19, 2014, which was 3137 days—8 years, 7 months, and 3 13 days—after the limitations period expired. See Second Amended Petition (ECF No. 126).

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Related

Houston v. Lack
487 U.S. 266 (Supreme Court, 1988)
Duncan v. Walker
533 U.S. 167 (Supreme Court, 2001)
Markel American Insurance v. Díaz-Santiago
674 F.3d 21 (First Circuit, 2012)
Mayle v. Felix
545 U.S. 644 (Supreme Court, 2005)
Ronald Ross v. Williams
950 F.3d 1160 (Ninth Circuit, 2020)
Castillo v. Nevada
526 U.S. 1031 (Supreme Court, 1999)

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William P. Castillo v. William Reubart, (DEATH PENALTY), Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-p-castillo-v-william-reubart-death-penalty-nvd-2022.