Humberto Mejia JR. v. State
Background
- Mejia pleaded guilty to felony domestic battery; judgment entered April 15, 2015, with retained jurisdiction later relinquished.
- Mejia completed and signed a pro se post-conviction petition on November 1, 2015, and prison records show legal mail containing the petition was sent to the court on November 5, 2015 (copy in record lacked a court stamp).
- Mejia filed a second pro se post-conviction petition that was stamped filed on June 21, 2016, and simultaneously moved for appointed counsel.
- The district court concluded Mejia’s post-conviction petition was untimely (treating only the June 21 filing as operative), dismissed the petition with prejudice, and denied appointment of counsel; Mejia appealed.
- The Court of Appeals applied the mailbox rule, held the November 5, 2015 mailing established a timely filing, and remanded for findings on the relationship between the two petitions (amendment, supplement, or successive) and on appointment of counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mejia timely filed a post-conviction petition | Mejia: first petition delivered to prison authorities Nov 5, 2015, so timely under mailbox rule | State: no court stamp; only June 21, 2016 filing is in court record and is untimely | Court: mailbox rule applies; Nov 5, 2015 petition is timely filed |
| Whether the June 21, 2016 petition relates back to the Nov 5, 2015 petition | Mejia: second petition is supplemental/amended and thus relates back | State: second petition is successive and does not relate back, so untimely | Court: unresolved—remanded to district court to determine relationship between petitions |
| Whether summary dismissal was proper without notice/opportunity to respond | Mejia: district court erred by dismissing without notice/response opportunity | State: court treated petition as unsupported by admissible evidence and untimely | Court: did not decide because timeliness of first petition controls; remand required for further proceedings |
| Whether Mejia was entitled to appointment of counsel | Mejia sought counsel contemporaneously with second petition | State opposed appointment based on petition deficiencies/untimeliness | Court: reversed denial and remanded for reconsideration in light of timely first filing |
Key Cases Cited
- Munson v. State, 128 Idaho 639, 917 P.2d 796 (Idaho 1996) (mailbox rule for pro se inmate filings)
- Hayes v. State, 143 Idaho 88, 137 P.3d 475 (Ct. App. 2006) (application of mailbox rule to inmate filings)
- Wolf v. State, 152 Idaho 64, 266 P.3d 1169 (Ct. App. 2011) (petition must be accompanied by admissible evidence or state why not)
- Charboneau v. State, 140 Idaho 789, 102 P.3d 1108 (Idaho 2004) (if petitioner’s evidence would entitle relief, summary dismissal inappropriate)
- Kelly v. State, 149 Idaho 517, 236 P.3d 1277 (Idaho 2010) (standards for summary dismissal of post-conviction claims)