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GOODMAN v. NEW JERSEY STATE PRISON
2:16-cv-04591
D.N.J.
Jun 20, 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: GOODMAN v. NEW JERSEY STATE PRISON
Court Name: District Court, D. New Jersey
Date Published: Jun 20, 2017
Docket Number: 2:16-cv-04591
Court Abbreviation: D.N.J.