Clayton v. Warden
3:25-cv-00512
| N.D. Ind. | Jun 27, 2025Background
- David Clayton, an Indiana prisoner, filed a habeas petition challenging his 2021 conviction and 25-year sentence for dealing methamphetamine in Morgan County, Indiana.
- He pleaded guilty to the state charge and did not pursue a direct appeal.
- Clayton argues the Indiana statute for dealing methamphetamine is constitutionally overbroad, relying on Aguirre-Zuniga v. Garland.
- The district court reviewed the claim under Rule 4 of the Section 2254 Habeas Corpus Rules, which requires dismissal if the petition plainly lacks merit.
- The court considered if Clayton’s claim was procedurally defaulted, untimely (one-year bar), and if it presented any cognizable federal constitutional issue.
- The court denied a certificate of appealability and ordered the case closed.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Whether Ind. Code § 35-48-4-1.1 is unconstitutionally overbroad | Statute is facially overbroad based on Seventh Circuit case | Removal precedent irrelevant for conviction | Claim fails; statute not overbroad constitutionally |
| Whether the habeas petition is procedurally defaulted | Not directly addressed | Did not exhaust or timely appeal | Petition procedurally defaulted/untimely |
| Applicability of Aguirre-Zuniga to state criminal conviction | Seventh Circuit found Indiana’s statute broader than federal definition | Statute’s breadth only relevant to immigration, not constitutionality | Aguirre-Zuniga inapplicable to claim |
| Applicability of First Amendment overbreadth doctrine | Statute overbroad under First Amendment principles | No free expression implicated | Doctrine irrelevant to statute at issue |
Key Cases Cited
- Timberlake v. State, 753 N.E.2d 591 (Ind. 2001) (issues known but not raised on direct appeal are waived in postconviction proceedings)
- Lewis v. Sternes, 390 F.3d 1019 (7th Cir. 2004) (habeas claim is procedurally defaulted if not raised at every level of state review)
- Massachusetts v. Oakes, 491 U.S. 576 (1989) (overbreadth doctrine is designed to protect free expression, not at issue here)
- Slack v. McDaniel, 529 U.S. 473 (2000) (standard for granting a certificate of appealability on procedural dismissals)