Roderick Bates v. Warden Brian Eller

Summary

The United States District Court for the Eastern District of Tennessee dismissed Roderick Bates’s petition for a writ of habeas corpus under 28 U.S.C. § 2254 as untimely under the AEDPA statute of limitations. The court granted the respondent’s motion to dismiss with prejudice and denied a certificate of appealability.

Holdings

1. The petition was untimely because the conviction became final on August 3, 2016, the limitations period ran for 273 days before state post-conviction proceedings tolled it, resumed on September 13, 2024, and expired on December 13, 2024; Bates did not file his federal petition until May 16, 2025.
2. Equitable tolling did not apply because Bates made no argument establishing that he had pursued his rights diligently or that an extraordinary circumstance prevented timely filing.
3. Bates did not overcome the limitations bar through actual innocence because he presented no credible showing that, in light of all the evidence, no reasonable juror would have convicted him.
4. A certificate of appealability was denied because reasonable jurists would not find it debatable that the petition was untimely.

Questions Presented

1. Whether Bates's 28 U.S.C. § 2254 petition was barred by AEDPA's one-year statute of limitations.
2. Whether statutory tolling during the state post-conviction proceedings rendered the federal petition timely.
3. Whether Bates established entitlement to equitable tolling or a credible showing of actual innocence sufficient to overcome the limitations bar.
4. Whether a certificate of appealability should issue after dismissal on procedural grounds.

Disposition

dismissed