Warfield v. Horton, 2:21-cv-10463

LaMichael Warfield was convicted in Michigan state court of first-degree criminal sexual conduct, kidnapping, and related offenses for a violent incident involving another inmate at Macomb County Jail.
Warfield was sentenced as a fourth-time habitual felony offender to 25–50 years in prison in 2018.
Warfield challenged his convictions in the Michigan Court of Appeals on grounds including insufficient evidence, prosecutorial misconduct, evidentiary rulings, denial of a speedy trial, and sentencing errors. The Court of Appeals affirmed his conviction.
He attempted to appeal to the Michigan Supreme Court, but his application was rejected as untimely, even after accounting for extensions due to COVID-19.
Warfield then filed a federal habeas corpus petition under 28 U.S.C. § 2254, raising the same five claims from his direct appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural default due to untimely appeal	COVID caused late filing; delay should be excused	Procedural rules enforced; Warfield's claims defaulted	Claims procedurally defaulted and barred
Sufficiency of evidence and trial errors	Evidence was insufficient; various trial errors impacted outcome	Claims not reviewable due to procedural default	Court barred from reviewing on merits
Cause & prejudice for excusing default	Cites COVID pandemic as cause	No specific showing of how COVID prevented filing	No sufficient cause or prejudice shown
Actual innocence exception to default	(Did not present new evidence; relied on assertions)	No plausible claim; no new reliable evidence presented	Actual innocence argument rejected

Coleman v. Thompson, 501 U.S. 722 (1991) (federal habeas review barred where procedural default occurs due to failure to follow state rules)
Murray v. Carrier, 477 U.S. 478 (1986) (actual innocence may excuse procedural default only with new reliable evidence)
Schlup v. Delo, 513 U.S. 298 (1995) (actual innocence exception requires credible new evidence of innocence)