Ring v. Lightle
655 F. App'x 657
| 10th Cir. | 2016Background
- Ronald Ring pleaded nolo contendere to state burglary charges and later learned Oklahoma law required serving 85% of the sentence before eligibility for early release (Okla. Stat. tit. 21, § 13.1).
- He filed a federal habeas petition under 28 U.S.C. § 2254 claiming he should have been informed of the 85% requirement at plea.
- The district court dismissed the petition as time-barred under the one-year statute of limitations for state prisoners, 28 U.S.C. § 2244(d)(1).
- Ring admitted he learned of the 85% requirement in 2009 but waited about five years before seeking state relief and then filed federal habeas after the limitations period.
- Ring raised alternate theories on appeal (void sentence, fraud on the court, actual innocence, and that the district court should have reached the merits first); the court found none of these rebutted the timeliness ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness under § 2244(d)(1) | Ring argued the petition was timely or that exceptions applied | Respondent argued the petition was untimely; limitations began when Ring discovered the factual predicate in 2009 | Court: Dismissal as time-barred was not debatable; limitations began when Ring learned of 85% rule and he filed years later |
| Void sentence / jurisdiction | Ring contended the state sentence was void | Respondent treated this as a merits claim unrelated to timeliness | Court: Jurisdictional claim is a merits issue, not a timeliness defense; does not avoid time bar |
| Fraud on the court | Ring argued he was defrauded because he was not told of the 85% requirement | Respondent argued no allegations of intent to deceive and cited high threshold for fraud on the court | Court: No plausible allegations of fraud on the court; cannot excuse limitations |
| Actual innocence | Ring argued actual innocence to avoid the limitations bar | Respondent argued actual innocence exception applies to factual innocence of the crime, not sentencing disputes | Court: Ring’s claim concerns time to be served, not innocence of burglary; McQuiggin exception inapplicable |
| Order of decision (merits vs. timeliness) | Ring argued court should have addressed merits first | Respondent moved only on timeliness; merits not yet briefed | Court: District court properly decided timeliness first; untimely claims cannot obtain habeas relief |
Key Cases Cited
- Slack v. McDaniel, 529 U.S. 473 (certificate of appealability standard when district court denies on procedural grounds)
- United States v. Williams, 790 F.3d 1059 (10th Cir. 2015) (courts can correct judgments based on fraud)
- Robinson v. Audi Aktiengesellschaft, 56 F.3d 1259 (10th Cir. 1995) (fraud on the court requires intent to deceive)
- McQuiggin v. Perkins, 569 U.S. 383 (actual innocence can overcome AEDPA time bar, but applies to factual innocence of the crime)
- Selsor v. Kaiser, 22 F.3d 1029 (10th Cir. 1994) (actual innocence exception pertains to the crime’s elements, not sentencing disputes)
- Rolland v. Primesource Staffing, LLC, 497 F.3d 1077 (10th Cir. 2007) (frivolous appeals and IFP denial)
- Weese v. Schukman, 98 F.3d 542 (10th Cir. 1996) (fraud on the court requires egregious misconduct)
- Rozier v. Ford Motor Co., 573 F.2d 1332 (5th Cir. 1978) (fraud-on-the-court standard; only extreme misconduct qualifies)