Winston v. Jeffreys

District Court, D. Nebraska·Decided May 21, 2025·No. 8:25-cv-00103·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

MARCUS D. WINSTON,

Petitioner, 8:25CV103

vs. MEMORANDUM AND ORDER ROB JEFFREYS,

Respondent.

This matter is before the Court on Petitioner’s Motion Requesting Leave to Amend and Extension of Time (“Motion to Amend”). Filing No. 6. In the Motion to Amend, Petitioner seeks leave to amend his petition, Filing No. 5, and an extension of time to do so until after all his state remedies are exhausted. Filing No. 6. Liberally construed, Petitioner appears to seek to stay this matter until his state court claims are exhausted. Rule 15 of the Federal Rules of Civil Procedure governs motions to amend petitions in habeas proceedings. See Mayle v. Felix, 545 U.S. 644, 655 (2005) (stating that Rule 15 is “made applicable to habeas proceedings by § 2242, Federal Rule of Civil Procedure 81(a)(2), and Habeas Corpus Rule 11”). Amendments are allowed one time as a matter of course if the amendment is filed within 21 days of service of a responsive pleading or a Rule 12 motion. Fed. R. Civ. P. 15(a)(1)(B). Moreover, an amended petition relates back to the date of the original petition when the claims in the original and amended petition arose out of the same “conduct, transaction, or occurrence,” Fed. R. Civ. P. 15(c)(1)(B); see also Mayle, 545 U.S. at 656, “such that they arise from the same core of operative facts,” United States v. Hernandez, 436 F.3d 851, 857 (8th Cir. 2006) (citing Mayle, 545 U.S. at 650, 657). Under the liberal amendment policy of Federal Rule of Civil Procedure 15(a), a district court’s denial of leave to amend pleadings is appropriate only in those limited circumstances in which undue delay, bad faith on the part of the moving partly [sic], futility of the amendment, or unfair prejudice to the non-moving party can be demonstrated.

Roberson v. Hayti Police Dep't, 241 F.3d 992, 995 (8th Cir. 2001) (footnote omitted) (citing Foman v. Davis, 371 U.S. 178, 182 (1962); Sanders v. Clemco Indus., 823 F.2d 214, 216 (8th Cir. 1987)). In support of his Motion to Amend, Petitioner explains that because he is unaware of how much time remains to file a timely petition under 28 U.S.C. § 2254, he rushed filing his Petition to be sure it was filed on time. Petitioner states he is in the process of filing a Writ of Certiorari to the United States Supreme Court, which may toll the one-year statute of limitations for filing a time § 2254 petition, and also has a pending motion to alter or amend judgment. Petitioner, thus, seeks leave to file an amended petition 210 days after all of his state remedies are exhausted. Filing No. 6. Petitioner, however, does not state that he omitted any claims from his habeas petition in his haste to file the petition in a timely manner and does not identify what, if any, specific claims he seeks to add or amend by filing an amended petition. Rather, Petitioner appears to seek leave to amend, and an extension of time to do so, in order to fully exhaust all of his state remedies and include such information regarding his exhaustion efforts in an amended petition. Thus, it appears that Petitioner may be claiming his petition is a “mixed petition”—meaning that “some claims have been fully exhausted in state court and others have not,” White v. Dingle, 616 F.3d 844, 846 (8th Cir. 2010)—and that he seeks to stay the case indefinitely so that he may fully exhaust his unexhausted state court claims. Petitioner is correct that time limits apply to his filing of a federal habeas petition. Under 28 U.S.C. § 2244(d)(1), a petitioner must file an application for a writ of habeas corpus within 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.

And, pursuant to Section 2244(d)(2), “[t]he 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.” When a mixed petition is filed, a petitioner may seek to stay federal review of their petition under Rhines v. Weber, 544 U.S. 269 (2005), which allows a federal habeas court to stay the petition to allow a petitioner to present his unexhausted claims to the state court and then to return to federal court for review. Under Rhines, a stay may only be granted if (1) the petitioner had good cause for failing to exhaust the previously unexhausted claims in state court, (2) the unexhausted claims are potentially meritorious, and (3) and the petitioner did not intentionally engage in dilatory tactics. 544 U.S. at 278. However, where a petition contains exhausted and unexhausted claims, courts do not have to stay the federal habeas proceedings if any attempt to exhaust the otherwise unexhausted claims in the state courts is “futile.” Armstrong v. Iowa, 418 F.3d 924, 926 (8th Cir. 2005). While Petitioner’s Motion to Amend did not address the Rhines factors, even if it had, it does not appear Petitioner’s petition is truly mixed based on his description of his pending Writ application to the United States Supreme Court.

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Winston v. Jeffreys, (D. Neb. 2025).

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Lawrence v. Florida
549 U.S. 327 (Supreme Court, 2007)
White v. Dingle
616 F.3d 844 (Eighth Circuit, 2010)
Mayle v. Felix
545 U.S. 644 (Supreme Court, 2005)
Tommy Joe Stutzka v. James P. McCarville
420 F.3d 757 (Eighth Circuit, 2005)