Richard A. Vaughn, Sr. v. Commonwealth of Pennsylvania, et al.

Summary

The United States District Court for the Middle District of Pennsylvania dismissed Richard A. Vaughn’s amended petition for a writ of habeas corpus under 28 U.S.C. § 2254 as untimely under AEDPA. The court rejected equitable tolling based on Vaughn’s alleged lack of trial transcripts and ignorance of the law, declined to issue a certificate of appealability, and directed the Clerk of Court to close the case.

Holdings

1. Vaughn's § 2254 petition was untimely because his state-court judgment became final on December 19, 2019, the federal limitations period expired on December 19, 2020 subject to statutory tolling, and the petition was not filed until August 25, 2025.
2. Equitable tolling was not warranted because Vaughn did not show diligent pursuit of his rights or an extraordinary circumstance that prevented timely filing.
3. No certificate of appealability should issue because reasonable jurists would not debate the procedural dismissal of Vaughn's untimely petition.

Questions Presented

1. Whether Vaughn's amended § 2254 petition was timely under AEDPA's one-year statute of limitations.
2. Whether statutory or equitable tolling applied to excuse the untimely filing.
3. Whether a certificate of appealability should issue following dismissal on procedural grounds.

Disposition

dismissed