Aldridge v. Holloway
2:14-cv-02874
W.D. Tenn.Jun 6, 2017Background
- Junior Aldridge filed a federal habeas petition under 28 U.S.C. § 2254 challenging a state-court evidentiary exclusion related to police testimony about the victim’s statements before his murder.
- The Court dismissed the § 2254 petition as untimely and denied a certificate of appealability (COA) and leave to appeal in forma pauperis; judgment was entered April 25, 2017.
- Aldridge, through appointed counsel, moved under Federal Rule of Civil Procedure 60(b) to set aside the portions of the dismissal order denying a COA and IFP status for appeal.
- At the underlying timeliness hearing the Court credited the prison unit manager over Aldridge on the chronology relevant to equitable tolling and concluded Aldridge failed to show actual-innocence gateway relief under McQuiggin.
- The Court reconsidered only the COA and good-faith certification aspects: it denied a COA on equitable tolling but granted a COA on the actual-innocence gateway issue and certified that an appeal addressing that issue would be taken in good faith.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether equitable tolling of AEDPA limitations applies | Aldridge contended prison restrictions justified tolling | Respondent argued the unit manager’s credible testimony disproved tolling | Court: No equitable tolling; not a debatable issue for COA |
| Whether Aldridge made a gateway actual-innocence showing under McQuiggin | Aldridge argued excluded police testimony, viewed with other weaknesses, makes it more likely than not no reasonable juror would convict | Respondent argued the record does not satisfy the McQuiggin probability standard | Court: Debateable among jurists; COA granted on actual-innocence issue |
| Whether a COA should issue on the procedural dismissal | Aldridge sought COA on both tolling and actual innocence | Respondent opposed issuance | Court: COA denied for equitable tolling; granted for actual-innocence only |
| Whether an appeal would be taken in good faith for IFP purposes | Aldridge sought certification that appeal would be in good faith to obtain IFP appeal | Respondent opposed | Court: Certified appeal would be taken in good faith only as to the actual-innocence issue; not otherwise |
Key Cases Cited
- McQuiggin v. Perkins, 569 U.S. 383 (2013) (actual-innocence gateway can excuse AEDPA time bar if more likely than not no reasonable juror would convict)
- Miller-El v. Cockrell, 537 U.S. 322 (2003) (standard for issuing a certificate of appealability)
- Slack v. McDaniel, 529 U.S. 473 (2000) (COA when procedural ruling is debatable among jurists)