GOODMAN v. NEW JERSEY STATE PRISON
2:16-cv-04591
D.N.J.Jun 20, 2017Background
- Petitioner Qur’an Goodman was convicted by a New Jersey jury of murder and weapons offenses and sentenced on February 5, 2007, to 30 years imprisonment with 30 years parole ineligibility.
- Goodman’s direct appeal was decided by the New Jersey Appellate Division (opinion issued Aug. 9, 2010) and the New Jersey Supreme Court denied certification on Jan. 7, 2011.
- Goodman filed a state post-conviction relief (PCR) petition on April 7, 2011; the Appellate Division reversed and remanded, the PCR court later denied relief, and the Appellate Division affirmed; New Jersey Supreme Court denied certification on May 19, 2016.
- Goodman filed a federal habeas petition under 28 U.S.C. § 2254 on July 29, 2016 (later amended Nov. 23, 2016). Respondents moved to dismiss the petition as time-barred under 28 U.S.C. § 2244(d).
- The central factual dispute relied on by the parties was whether Goodman’s notice of direct appeal was timely filed at sentencing (Goodman says yes; respondents produced a later-filed notice), because that affects when the one-year AEDPA limitations period began to run.
- The District Court denied respondents’ motion to dismiss, ruling Goodman’s conviction became final on April 7, 2011 (when the certiorari period expired), and that Goodman’s timely-filed PCR tolled the limitations period so the federal petition was timely.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did Goodman’s judgment become "final" under § 2244(d)(1)(A)? | Goodman: direct appeal was timely (signed at sentencing), so finality follows conclusion of direct review. | Respondents: notice of appeal was filed late (Oct 31, 2007), which would make AEDPA clock start earlier and render petition untimely. | Court: Finality occurs after conclusion of direct review and certiorari period; judgment became final April 7, 2011. |
| Was the federal habeas petition timely given AEDPA tolling? | Goodman: timely — he filed PCR on April 7, 2011, which tolled AEDPA; petition filed July 29, 2016, within limitations. | Respondents: untimely — calculation yields 456 days outside limitations due to alleged late direct appeal. | Court: PCR filing tolled limitations immediately; state collateral proceedings ended May 19, 2016; federal petition filed within one year, so timely. |
Key Cases Cited
- Kapral v. United States, 166 F.3d 565 (3d Cir. 1999) (defines when a criminal judgment is "final" for habeas purposes relative to direct review and certiorari period)
- Swartz v. Meyers, 204 F.3d 417 (3d Cir. 2000) (judgment is final after expiration of the 90-day certiorari period following state high-court review)
- Pace v. DiGuglielmo, 544 U.S. 408 (2005) (properly filed state post-conviction applications toll AEDPA limitations)
- Jimenez v. Quarterman, 555 U.S. 113 (2009) (an out-of-time direct appeal granted during state collateral review prevents a conviction from being "final" for AEDPA until direct review completes)
- Lawrence v. Florida, 549 U.S. 327 (2007) (state review concludes for tolling purposes when the state’s highest court has denied review or issued its mandate)
