Junior Aldridge v. Shawn Phillips
714 F. App'x 562
| 6th Cir. | 2017Background
- Junior Aldridge was convicted in Tennessee state court of first-degree murder and especially aggravated robbery; sentenced to life and 40 years concurrently.
- Direct and state post-conviction efforts failed; Aldridge filed a § 2254 habeas petition in federal court but conceded it was filed after the one-year § 2244(d) limitations period.
- Aldridge argued actual innocence would equitably toll the limitations period based on evidence not admitted at trial: a statement by the murder victim, Travis Clariett, two days before his death implicating Renarda Irving in taking his car and threatening him.
- Trial evidence included eyewitness testimony (Jeremy Hull) and Irving’s testimony that Aldridge approached the victim’s Cadillac, pulled a gun from a plastic bag, ordered the window down, and fired the fatal shot; Hull identified Aldridge as the shooter and saw no weapon in Irving’s hands.
- The trial court excluded Clariett’s pre-death statement as hearsay; Aldridge claimed that, if admitted, it combined with other evidence to show he was actually innocent.
- The district court dismissed the habeas petition as untimely; the Sixth Circuit affirmed, finding Aldridge failed to meet the stringent actual-innocence gateway standard.
Issues
| Issue | Aldridge's Argument | State's Argument | Held |
|---|---|---|---|
| Whether actual innocence can excuse untimely § 2254 filing | Clariett’s pre-death statement pointing to Irving shows actual innocence and should equitably toll § 2244(d) | No actual-innocence showing; trial evidence still supports conviction | Denied—actual-innocence gateway not met; petition untimely |
| Whether Clariett’s statement, if considered, makes it more likely than not no reasonable juror would convict | Statement combined with trial evidence would redirect suspicion to Irving | Statement is insufficient; no evidence Irving had a gun or fired the shot | Denied—reasonable juror could still convict Aldridge |
| Standard for actual-innocence gateway applicability | Schlup/McQuiggin standard allows gateway if more likely than not no reasonable juror would convict | Standard applies; Aldridge fails to satisfy it | Applied standard; Aldridge fails to meet burden |
| Whether newly presented (but not newly discovered) evidence can satisfy gateway | Yes—newly presented evidence may qualify | Agrees in principle but contends evidence here is inadequate | Court: newly presented evidence can qualify, but these facts do not suffice |
Key Cases Cited
- McQuiggin v. Perkins, 569 U.S. 383 (2013) (actual-innocence gateway may permit review of otherwise time-barred habeas petitions)
- Schlup v. Delo, 513 U.S. 298 (1995) (actual-innocence standard: petitioner must show it is more likely than not no reasonable juror would convict in light of new evidence)
- Souter v. Jones, 395 F.3d 577 (6th Cir. 2005) (narrow application of the Schlup gateway; guidance on evaluating new evidence)
- Cleveland v. Bradshaw, 693 F.3d 626 (6th Cir. 2012) (clarifies that "new evidence" may include evidence not presented at trial)