Jones v. Holt
Civil Action No. 2016-1087
| D.D.C. | May 17, 2017Background
- In April 2001, Jones was convicted in D.C. Superior Court of first-degree murder while armed, second-degree murder while armed, and weapons offenses; he is serving a life sentence.
- His convictions were affirmed on direct appeal and he filed post-conviction petitions in D.C. courts; a 2009 D.C. Court of Appeals decision affirmed denial of his first post-conviction petition.
- In June 2016 Jones filed a federal habeas petition under 28 U.S.C. § 2254 alleging ineffective assistance of counsel on direct appeal.
- The government moved to dismiss, arguing the petition is time-barred by AEDPA’s one-year statute of limitations and § 2254(i) bars claims of counsel ineffectiveness in collateral proceedings.
- The court calculated the conviction became final for AEDPA purposes no later than November 18, 2009, making the federal petition due by November 18, 2010.
- Jones did not seek equitable tolling or otherwise justify delay; the court dismissed the petition as untimely and declined to reach § 2254(i).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jones’s § 2254 petition is time-barred under AEDPA | Jones filed in June 2016 and seeks relief for appellate counsel ineffectiveness | Petition became final by Nov. 18, 2009; AEDPA’s one-year limit expired Nov. 18, 2010; no tolling applies | Petition dismissed as untimely |
| Whether AEDPA tolling applied for state post-conviction proceedings | Jones relies on state collateral filings to justify timeliness | AEDPA tolling does not extend for certiorari or was not shown to apply to delay here | No tolling shown; statute of limitations expired |
| Whether equitable tolling saves the petition | Jones did not present grounds or evidence for equitable tolling | Government argues no basis for equitable tolling in the record | Court found no basis for equitable tolling |
| Whether § 2254(i) bars claims premised on counsel ineffectiveness in collateral proceedings | Jones claims ineffective assistance on direct appeal (not collateral?) | Government invoked § 2254(i) as an alternative bar | Court did not resolve § 2254(i) because petition dismissed on statute-of-limitations grounds |
Key Cases Cited
- Head v. Wilson, 792 F.3d 102 (D.C. Cir. 2015) (AEDPA’s time and equitable-tolling principles apply to D.C. prisoners)
- Lawrence v. Florida, 549 U.S. 327 (2007) (AEDPA tolling does not cover the pendency of a certiorari petition)
- Jones v. Holt, 814 F. Supp. 2d 4 (D.D.C. 2011) (district-court summary of petitioner’s convictions and prior proceedings)