Eaglin v. Louisiana
| Decision Date | 07 January 2020 |
| Docket Number | CIVIL ACTION NO. 19-9659 SECTION: "I"(3) |
| Parties | KEEFER LAMAR EAGLIN v. STATE OF LOUISIANA |
| Court | U.S. District Court — Eastern District of Louisiana |
Petitioner, Keefer Lamar Eaglin, is a Louisiana state prisoner incarcerated at the Dixon Correctional Institute in Jackson, Louisiana. He filed this federal application seeking habeas corpus relief pursuant to 28 U.S.C. § 2254. For the following reasons, it is recommended that the application be DISMISSED WITH PREJUDICE.
On November 21, 2013, petitioner was convicted of forcible rape under Louisiana law.1 On March 28, 2014, he was found to be a second offender and was sentenced as such to a term of eighty years imprisonment without benefit of probation, parole, or suspension of sentence.2 On April 24, 2015, the Louisiana First Circuit Court of Appeal affirmed his conviction, habitual offender adjudication, and sentence.3 The Louisiana Supreme Court then denied his related writ application on April 15, 2016.4
On March 17, 2017, petitioner filed an application for post-conviction relief with the state district court.5 That application was denied on April 27, 2017.6 His related writ applications were then likewise denied by the Louisiana First Circuit Court of Appeal on September 15, 2017,7 and February 20, 2018,8 and by the Louisiana Supreme Court on March 6, 2019.9
On April 18, 2019, petitioner filed the instant federal application seeking habeas corpus relief pursuant to 28 U.S.C. § 2254.10 The state opposes the application.11
Under the Antiterrorism and Effective Death Penalty Act of 1996 ("AEDPA"), a petitioner is generally required to bring his § 2254 claims within one (1) year of the date on which his underlying state criminal judgment became "final." 28 U.S.C. § 2244(d)(1)(A).12 With respect to determining the date of finality, the United States Fifth Circuit Court of Appeals has explained:
Butler v. Cain, 533 F.3d 314, 317 (5th Cir. 2008).
In its response in this proceeding, the state halfheartedly argues that petitioner's federal application may be untimely because his direct-review writ application may have been untimely filed with the Louisiana Supreme Court. However, the state speculates that the Court may reject that argument because the state bears the burden of proof on this affirmative defense, see Ray v. Clements, 700 F.3d 993, 1006-12 (7th Cir. 2012), and it has no proof that the writ application was in fact untimely.13
The defense should indeed be rejected. Because the Louisiana Supreme Court's decision did not expressly hold that petitioner's direct-review writ application was untimely, and because the state has submitted no evidence showing that the application was in fact untimely, there is not an adequate basis for this Court to conclude that the Louisiana Supreme Court denied the application as untimely.
Accordingly, pursuant to Butler, the Court finds that petitioner's state criminal judgment became final for AEDPA purposes on July 14, 2016, i.e. ninety days after the Louisiana Supreme Court denied the direct-review writ application on the merits. As a result, his federal limitations period commenced on that date and then expired one year later, unless that deadline was extended through tolling.
Regarding the statute of limitations provided in § 2244, the AEDPA states: "The time during which a properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim is pending shall not be counted toward any period of limitation under this subsection." 28 U.S.C. § 2244(d)(2).
After two hundred forty-five (245) days elapsed, petitioner tolled the federal limitations period by filing a post-conviction application with the state district court on March 17, 2017. That application then remained pending - and the federal limitations period therefore remained tolled - for the duration of the post-conviction proceedings, so long as petitioner continued to seek review at the higher levels of the state court system in a timely manner. Grillette v. Warden, Winn Correctional Center, 372 F.3d 765, 769-71 (5th Cir. 2004). Here, the state does not argue that petitioner's related collateral-review writ applications were untimely. Accordingly, the Court finds that the limitations period remained tolled until the Louisiana Supreme Court denied post-conviction relief on March 6, 2019.
When the limitations period then resumed running at that point, petitioner had one hundred twenty (120) days remaining. Because he filed his federal application a mere forty-three (43) dayslater, it was timely. In light of that fact, and because the state does not allege that petitioner's claims are unexhausted or procedurally barred,14 the Court will review the claims on the merits.
The AEDPA comprehensively overhauled federal habeas corpus legislation, including 28 U.S.C. § 2254. Amended subsections 2254(d)(1) and (2) contain revised standards of review for pure questions of fact, pure questions of law, and mixed questions of both. The amendments modified a federal habeas court's role in reviewing state prisoner applications in order to prevent federal habeas 'retrials' and to ensure that state-court convictions are given effect to the extent possible under law." Bell v. Cone, 535 U.S. 685, 693 (2002); accord Langley v. Prince, 926 F.3d 145, 155 (5th Cir. 2019) ().
As to pure questions of fact, factual findings are presumed to be correct and a federal court will give deference to the state court's decision unless it "was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding." 28 U.S.C. § 2254(d)(2); see also 28 U.S.C. § 2254(e)(1) ( ).
As to pure questions of law and mixed questions of law and fact, a federal court must defer to the state court's decision on the merits of such a claim unless that decision "was contrary to, orinvolved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States." 28 U.S.C. § 2254(d)(1). Courts have held that the "'contrary to' and 'unreasonable application' clauses [of § 2254(d)(1)] have independent meaning." Bell, 535 U.S. at 694.
Regarding the "contrary to" clause, the United States Fifth Circuit Court of Appeals has explained:
A state court decision is contrary to clearly established precedent if the state court applies a rule that contradicts the governing law set forth in the [United States] Supreme Court's cases. A state-court decision will also be contrary to clearly established precedent if the state court confronts a set of facts that are materially indistinguishable from a decision of the [United States] Supreme Court and nevertheless arrives at a result different from [United States] Supreme Court precedent.
Wooten v. Thaler, 598 F.3d 215, 218 (5th Cir. 2010) ().
Regarding the "unreasonable application" clause, the United States Supreme Court has held: "[A] state-court decision is an unreasonable application of our clearly established precedent if it correctly identifies the governing legal rule but applies that rule unreasonably to the facts of a particular prisoner's case." White v. Woodall, 572 U.S. 415, 426 (2014). However, a federal habeas court must be mindful that "an unreasonable application is different from an incorrect one." Bell, 535 U.S. at 694; accord Harrington v. Richter, 562 U.S. 86, 102-03 (2011) ...
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