Huntley v. Elayn Hunt Correctional Center
6:13-cv-02633
W.D. La.Dec 13, 2013Background
- Huntley was convicted of second-degree murder in Vermilion Parish, Louisiana in 1983 and sentenced to life; conviction affirmed on direct appeal in 1985.
- He filed multiple state and federal post-conviction/habeas petitions over the years; earliest state collateral relief was denied in 1992; later state writs were denied in 1999, 2000, 2012, and 2013.
- The instant federal habeas petition was filed (mailbox rule) on September 3, 2013, asserting ineffective assistance of trial counsel for failing to obtain a 1982 crime lab report allegedly showing a Caucasian hair on the victim.
- AEDPA’s one-year statute of limitations applies; because Huntley’s conviction became final in 1985, he had a “grace period” until April 24, 1997 to file federal habeas petitions arising from that conviction.
- No properly filed state collateral proceeding was pending during the AEDPA grace period, and Huntley waited decades before asserting the lab-report-based claim.
- The magistrate judge concluded the petition is time-barred under 28 U.S.C. § 2244(d) and denied equitable tolling and § 2244(d)(1)(C)/Martinez-based relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness under AEDPA §2244(d) | Huntley asserts ineffective assistance based on newly discovered lab report; petition filed 2013 should be considered timely under some tolling theory | State argues conviction was final in 1985 so Huntley’s AEDPA grace period expired April 24, 1997; 2013 petition is untimely | Petition is untimely and barred by §2244(d); dismissed with prejudice |
| Statutory tolling for state collateral proceedings (§2244(d)(2)) | Huntley points to multiple state applications filed later as grounds to toll limitations | State shows no properly filed state post-conviction was pending during the 1996–1997 grace period; prior state filings were much earlier or untimely | No statutory tolling applies because no proper state proceedings were pending during AEDPA grace period |
| Equitable tolling / diligence | Huntley implies delay justified by late discovery of lab report and lack of counsel | State contends Huntley slept on his rights; evidence was discoverable earlier; no extraordinary circumstances | Equitable tolling denied: petitioner failed to show extraordinary circumstances or due diligence |
| Applicability of Martinez v. Ryan to restart limitations | Huntley relies on Martinez to excuse procedural defaults and justify tolling | State and court treat Martinez as equitable, not a new constitutional right that restarts AEDPA clock | Martinez does not create a new constitutional right under §2244(d)(1)(C); it does not render untimely petition timely |
Key Cases Cited
- Martinez v. Ryan, 132 S. Ct. 1309 (2012) (announcing limited equitable exception to Coleman procedural-default rule for ineffective-assistance-in-initial-review-collateral-proceedings claims)
- Duncan v. Walker, 533 U.S. 167 (2001) (federal habeas petitions do not toll AEDPA limitations)
- Holland v. Florida, 130 S. Ct. 2549 (2010) (equitable tolling requires diligence and extraordinary circumstances)
- Coleman v. Thompson, 501 U.S. 722 (1991) (procedural default rule; generally no right to counsel in collateral proceedings)
- Houston v. Lack, 487 U.S. 266 (1988) (mailbox rule for prisoner filings)
- Flanagan v. Johnson, 154 F.3d 196 (5th Cir. 1998) (AEDPA finality/tolling principles)
- Ott v. Johnson, 192 F.3d 510 (5th Cir. 1999) (statutory tolling for properly filed state collateral petitions)