Nathan Chambliss v. Harold Clarke
670 F. App'x 92
| 4th Cir. | 2016Background
- Nathan Chambliss filed a 28 U.S.C. § 2254 petition challenging his conviction; the district court referred it to a magistrate judge.
- The magistrate judge recommended denial and dismissal with prejudice based on unexcused procedural default and warned that failure to timely file specific objections would waive appellate review.
- Chambliss filed an objection; the district court overruled it, adopted the magistrate judge’s recommendation, granted the respondent’s motion to dismiss, and denied the § 2254 petition.
- Chambliss moved for relief under Fed. R. Civ. P. 59(e); the district court denied that motion.
- Because appeals from denials of § 2254 relief require a certificate of appealability (COA), the court reviewed whether Chambliss made a substantial showing of the denial of a constitutional right.
- The court concluded Chambliss waived appellate review of the § 2254 dismissal for procedural default and that he failed to make the showing required for a COA on the Rule 59(e) denial; it denied COA and IFP and dismissed the appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the § 2254 petition could proceed despite the magistrate judge’s finding of procedural default | Chambliss objected to the recommendation and sought review on the merits | Respondent argued the petition was procedurally defaulted and should be dismissed | Chambliss waived appellate review by failing to timely and specifically object as warned; dismissal for procedural default stands |
| Whether a certificate of appealability should issue for the Rule 59(e) denial | Chambliss sought COA to appeal the denial of his Rule 59(e) motion | Respondent argued Chambliss did not make the substantial showing required for COA | Court independently reviewed the record and found Chambliss did not satisfy COA standards; COA denied |
Key Cases Cited
- Slack v. McDaniel, 529 U.S. 473 (U.S. 2000) (standard for COA when relief denied on procedural or merits grounds)
- Miller-El v. Cockrell, 537 U.S. 322 (U.S. 2003) (clarifies COA showing and review standards)
- Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310 (4th Cir. 2005) (timely, specific objections to magistrate recommendations preserve appellate review)
- Wells v. Shriners Hosp., 109 F.3d 198 (4th Cir. 1997) (same: objections required to preserve review)
- Wright v. Collins, 766 F.2d 841 (4th Cir. 1985) (same: consequence of failing to timely object to magistrate recommendations)