Williams v. Fahey

82 Va. Cir. 178, 2011 Va. Cir. LEXIS 159
CourtNorfolk County Circuit Court
DecidedFebruary 2, 2011
DocketCase No. (Civil) CL10-4331; Case No. (Civil) CL10-5111; Case No. (Civil) CL10-5741
StatusPublished
Cited by1 cases

This text of 82 Va. Cir. 178 (Williams v. Fahey) is published on Counsel Stack Legal Research, covering Norfolk County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williams v. Fahey, 82 Va. Cir. 178, 2011 Va. Cir. LEXIS 159 (Va. Super. Ct. 2011).

Opinion

By Judge Everett A. Martin, Jr.

It is appropriate to state at the outset what I am not deciding. I am not deciding whether the petitioners are guilty or innocent of the rape and murder of Michelle Moore-Bosko or, in the case of Mr. Wilson, her rape. I am not deciding whether a jury would convict or acquit the petitioners [179]*179of those charges were they to be re-tried today. I am not deciding whether their confessions were voluntary or coerced. I am only deciding if they have timely filed their petitions for writs of habeas corpus. I find they have not done so.

The Suspension Clause

The petitioners claim the Suspension Clause of the Constitution of Virginia, Art. I, § 9, cl. 2, requires an exception to Code of Virginia § 8.01-654(A)(2) for claims based on newly discovered evidence that could not have been obtained through reasonable diligence within the limitations period. That clause provides “that the privilege of the writ of habeas corpus shall not be suspended unless when, in cases of invasion or rebellion the public safety may require.” The Supreme Court of Virginia has twice declined to decide the issue. Haas v. Lee, 263 Va. 273, 560 S.E.2d 256 (2002); Hines v. Kuplinski, 267 Va. 1, 591 S.E.2d 692 (2004).

In Boyce v. Braxton, No. CR70H34158 (Circuit Court of Newport News, Jan. 30, 2006), Judge Tench held that “for newly discovered evidence, such an exception must be read into the statute lest the statute of limitations operate in violation of the Suspension Clause. . . .” The petitioners claim Judge Doyle, who was later designated to hear Boyce, also adopted this rationale. Judge Doyle only denied a motion to reconsider the ruling. He may have agreed with the ruling or, as a prudent trial judge, he may simply have declined to revisit a decision made in the case almost four years earlier. From a review of a transcript of a hearing before Judge Doyle, Exh. R2 to respondent’s Reply to Opposition in Williams’s case, the latter appears more likely.

I also conclude I need not reach the issue, but I have doubts about the ruling in Boyce. The present version of Virginia’s Suspension Clause is almost identical to that of the federal constitution; “rebellion” and “invasion” are transposed and “it” is omitted at the end. It first appeared in the Constitution of 1869, Art. V, § 14. The use of the writ in post-conviction proceedings in the federal courts was then quite limited. The court inquired if the trial court had jurisdiction over the prisoner and the offense of which he was convicted and if the offense was one for which a person could be confined. If these inquiries were answered in the affirmative, the writ was denied unless the action of the trial court was otherwise void, as, for example, punishing a person twice for the same crime. Ex parte Kearney, 20 U.S. (7 Wheat.) 38 (1822); Ex parte Lange, 85 U.S. (18 Wall.) 163 (1874); Ex parte Parks, 93 U.S. 18 (1876). In 1867, Congress expanded the scope of the federal writ to “all cases where any person may be restrained of his or her liberty in violation of the constitution, or of any treaty of law of the United States.” This was not held applicable to state court convictions [180]*180until “well into” the twentieth century. Felkner v. Turpin, 518 U.S. 651, 663 (1998).

In the years following 1869, the use of the writ was similarly quite limited in post-conviction proceedings in Virginia. If a person was detained by virtue of a judgment of a court of competent jurisdiction, his imprisonment was not unlawful, Ex parte Marx, 86 Va. 40, 44, 9 S.E. 475, 477 (1889), unless, for example, he was confined for a cause for which a man ought not to be imprisoned pursuant to an unconstitutional statute or the proceeding that detained him was void. Ex parte Rollins, 80 Va. 314, 316-37 (1885).

In its opinion in Parks, the Supreme Court cited several English authorities on the limits on the use of the writ in post-conviction proceedings and stated:

The general principles upon which the writ of habeas corpus is issued in England were well settled by usage and statutes long before the period of our national independence, and must have been in the mind of Congress when the power to issue the writ was given to the courts and judges of the United States. These principles, subject to the limitations imposed by the Federal Constitution and laws, are to be referred to for our guidance on the subject.

93 U.S. at 21. Perhaps these decisions and principles should also be referred to in deciding what Virginia’s Suspension Clause protects.

Most courts have upheld statutes of limitations on the filing of petitions for writs of habeas corpus and for a sound reason. The use of the writ in post-conviction proceedings today is much changed from 1787 or 1869. See Felkner v. Turpin, supra. The late Justice Powell referred to the then present use of federal habeas corpus as “a revisionist concept. . . that bears little or no relationship to the historic purpose and function of the Great Writ.” Remarks on the 200th Anniversary of the Establishment of the Supreme Court of Virginia, 220 Va. at xvii (Aug. 30, 1979). The writ is rarely used today to challenge a trial court’s jurisdiction. Allegations of ineffective assistance of counsel or police or prosecutorial misconduct are far more common. The statute of limitations was probably not enacted to suspend the writ, but to reduce prisoner litigation and to try to bring finality to criminal convictions, a finality that has been undermined by the contemporary use of the writ.

Even if I accept the ruling in Boyce, the petitions are untimely. As I stated in my letter of September 15, 2010, to Mr. Allen and Ms. Theisen, copies of which I enclose for Ms. Worthington and Mr. Northup, Williams’s petition was not filed within a “reasonable time” (what Judge Tench held

[181]*181to be the necessary extension of the statute of limitations, and in Boyce it was one year) after the discovery of the claims. Derek Tice’s attorneys were able to investigate, prepare a petition and a 79-page memorandum in support of the petition, and file it on September 14, 2005, four years and nine months before Williams filed his petition, four years and ten months before Dick filed his, and almost five years before Wilson filed.

Williams s Motion To Reconsider the Order of December 17

I struck paragraphs 8 through 16 of Mr. Saltzman’s affidavit by the order objected to. I struck paragraphs 8 through 13 because they were hearsay. I struck paragraphs 14 and 15 because they were completely redacted. Neither respondent nor I know their content. However, by that same order, I allowed Williams to file exhibits and other affidavits based on the personal knowledge of the affiant. He has now submitted an affidavit of B. Frank Stokes and another affidavit of Mr. Saltzman. In their affidavits, Mr. Stokes and Mr. Saltzman state that a number of witnesses are reluctant to provide information from fear of retaliation or prosecution and that the Norfolk Police Department will not cooperate with them.

Williams filed his Petition on June 29,2010.

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Related

Hicks v. Clarke
87 Va. Cir. 208 (Norfolk County Circuit Court, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
82 Va. Cir. 178, 2011 Va. Cir. LEXIS 159, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-fahey-vaccnorfolk-2011.