William B. Rowan v. Jefferey Perkins

Summary

The United States District Court for the Eastern District of Washington dismissed William B. Rowan’s pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254 with prejudice. The court found that Rowan failed to amend the petition as directed and that his claims concerning the constitutionality of Washington’s non-corroboration statute were not cognizable habeas claims; it also denied a certificate of appealability.

Holdings

1. The action was properly dismissed with prejudice under Rule 4 because petitioner failed to comply with the court's order to amend the deficient petition within sixty days.
2. Petitioner's challenge to the constitutionality of RCW 9A.44.020(1), a state non-corroboration statute, was not a cognizable federal habeas claim.
3. Petitioner failed to demonstrate that his federal habeas petition was timely or that each claim was properly exhausted.

Questions Presented

1. Whether the deficient § 2254 petition should be dismissed after petitioner failed to amend it as ordered.
2. Whether a federal habeas claim challenging the constitutionality of RCW 9A.44.020(1), a state non-corroboration statute, is cognizable.
3. Whether petitioner demonstrated that the petition was timely and that each claim was properly exhausted.

Disposition

dismissed