Derrell J. Chamblee v. State of Florida
905 F.3d 1192
11th Cir.2018Background
- In 2010 Chamblee was convicted in Florida and sentenced to 25 years; the judgment also imposed court costs ($225 and $20) and a $50 assessment characterized (in 2003 law) as a fine.
- On direct appeal the Florida First DCA (Aug. 8, 2012) affirmed the conviction and sentence but vacated the costs and the $50 fine, remanding to the trial court to consider re-imposition of the fine only after appropriate findings; the mandate issued Aug. 24, 2012.
- The state trial court never acted on the DCA remand; Chamblee did not seek to enforce the mandate.
- Chamblee filed a Rule 3.800(c) motion (Oct. 23, 2012) and later a Rule 3.850 post-conviction motion (May 20, 2014); the courts treated the judgment as final and adjudicated the 3.850 motion on the merits.
- Chamblee filed a federal § 2254 petition on Oct. 28, 2015. The State moved to dismiss as untimely under AEDPA; the district court dismissed and this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did Chamblee's judgment become "final" under AEDPA § 2244(d)(1)(A)? | Chamblee: judgment never became final because the DCA remand remained pending in the trial court, so AEDPA clock never began. | State: DCA affirmed judgment in all other respects; time to seek certiorari expired 90 days after DCA decision, so judgment became final then and AEDPA clock began. | Court: Judgment was final when the DCA issued its decision/mandate and the 90‑day certiorari period expired; AEDPA limitations period ran from Nov. 6, 2012 (with statutory tolling for pending Rule 3.800(c) motion). |
Key Cases Cited
- Jimenez v. Quarterman, 555 U.S. 113 (2009) (AEDPA finality tied to completion of the state direct-review process)
- Bradshaw v. Richey, 546 U.S. 74 (2005) (federal habeas courts bound by state courts’ interpretation of state law)
- Patterson v. Sec'y, Fla. Dep't of Corr., 849 F.3d 1321 (11th Cir. 2017) (the relevant judgment is the one authorizing confinement)
- Ferreira v. Sec'y, Dep't of Corr., 494 F.3d 1286 (11th Cir. 2007) (defining which state-court orders constitute the judgment for AEDPA purposes)
- Herring v. Sec'y, Dep't of Corr., 397 F.3d 1338 (11th Cir. 2005) (federal habeas courts defer to state courts on state-law matters)