Stalter v. PA State Attorney General
1:17-cv-00697
M.D. Penn.Jan 10, 2018Background
- In Nov. 2007, Donald E. Stalter pleaded guilty in Dauphin County, PA to multiple sexual-offense counts and was sentenced on Apr. 21, 2008 to 20–40 years imprisonment.
- Stalter appealed; the Pennsylvania Superior Court affirmed and the Pennsylvania Supreme Court denied review in Feb. 2010; no certiorari petition was filed, so the judgment became final on May 4, 2010.
- Stalter filed a coram nobis application on Apr. 24, 2014, which the trial court dismissed; the Superior Court treated that filing as a first PCRA petition and remanded for counsel and further proceedings.
- A subsequent PCRA petition was denied by the trial court on Mar. 25, 2016; Stalter did not appeal that denial to the state appellate courts.
- Stalter filed a federal habeas petition under 28 U.S.C. § 2254 on Apr. 19, 2017, challenging the validity of his guilty plea.
- The district court found the § 2254 petition untimely under AEDPA, concluded the state collateral filings did not statutorily toll the limitations period, and declined to apply equitable tolling; it denied the petition and refused a certificate of appealability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stalter's § 2254 petition was timely under AEDPA | Stalter sought habeas relief challenging his guilty plea and relied on his later state collateral proceedings to justify delay | The judgment became final May 4, 2010; AEDPA one-year period expired May 4, 2011; state collateral filings were filed after expiration and therefore do not statutorily toll; no extraordinary circumstances justify equitable tolling | Petition untimely; statutory tolling inapplicable because PCRA was filed after AEDPA expired; equitable tolling denied for lack of diligence or extraordinary circumstances |
| Whether the coram nobis/PCRA filing tolled AEDPA limitations | The coram nobis/PCRA filing should toll or otherwise preserve his federal filing deadline | Because the one-year AEDPA period had already expired before the coram nobis/PCRA was filed, that state filing cannot statutorily toll the federal limitations period | State collateral filing had no tolling effect (Long v. Wilson principle applied) |
| Whether equitable tolling applies | Stalter contended (implicitly) that circumstances justified late filing | No evidence of active government misleading, extraordinary prevention, timely but mistaken filing in wrong forum, or court misdirection; no diligence shown | Equitable tolling denied; petitioner failed to show extraordinary circumstances plus diligence |
| Whether a Certificate of Appealability (COA) should issue | Stalter would argue his claims raise debatable constitutional issues | Because denial was on procedural timeliness grounds and the procedural ruling was not debatable, jurists of reason would not find it debatable | COA denied |
Key Cases Cited
- Jones v. Morton, 195 F.3d 153 (3d Cir. 1999) (examples of extraordinary circumstances warranting equitable tolling)
- Nara v. Frank, 264 F.3d 310 (3d Cir. 2001) (when judgment becomes final for AEDPA purposes)
- Long v. Wilson, 393 F.3d 390 (3d Cir. 2004) (state collateral filing after AEDPA expiration does not toll)
- Pace v. DiGuglielmo, 544 U.S. 408 (2005) (standards for equitable tolling and statutory tolling interplay)
- Satterfield v. Johnson, 434 F.3d 185 (3d Cir. 2006) (equitable tolling is rare and extraordinary)
- LaCava v. Kyler, 398 F.3d 271 (3d Cir. 2005) (limitations on equitable tolling; excusable neglect insufficient)
- Merritt v. Blaine, 326 F.3d 157 (3d Cir. 2003) (equity standard for tolling when rigid application is unfair)
- Robinson v. Johnson, 313 F.3d 128 (3d Cir. 2002) (duty to pursue rights diligently for equitable tolling)
- Miller-El v. Cockrell, 537 U.S. 322 (2003) (standard for granting a certificate of appealability)
- Slack v. McDaniel, 529 U.S. 473 (2000) (COA standards when habeas denied on procedural grounds)