Jevauhn Marcel Hampton v. State of Oregon

Summary

The United States District Court for the District of Oregon denied Jevauhn Marcel Hampton’s petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court held that the petition was barred by the one-year AEDPA statute of limitations and that Hampton had not established a basis for equitable tolling, and it denied a certificate of appealability.

Holdings

1. A state prisoner’s § 2254 petition is untimely when filed more than one year after the state judgment becomes final, absent applicable delayed accrual or tolling. Hampton's convictions became final on May 7, 2022, and his later federal petition was filed outside the one-year limitations period.
2. Even assuming that Hampton's mandamus petition constituted a properly filed application for state collateral review, it did not toll or revive the federal limitations period because it was filed after that period had already expired.
3. Hampton failed to demonstrate a basis for equitable tolling that would render his federal habeas petition timely.
4. A certificate of appealability was denied because Hampton did not make a substantial showing of the denial of a constitutional right.

Questions Presented

1. Whether Hampton's federal habeas petition was barred by AEDPA's one-year statute of limitations.
2. Whether the later-filed state mandamus petition statutorily tolled or revived the already-expired federal limitations period.
3. Whether Hampton was entitled to equitable tolling or a certificate of appealability.

Disposition

dismissed