Supreme Born v. Karen Williams

Summary

The United States District Court for the Northern District of Alabama adopted the Magistrate Judge’s recommendation and dismissed Supreme Born’s federal habeas corpus petition with prejudice as untimely. The court rejected Born’s arguments concerning the limitation-period trigger, statutory and equitable tolling, actual innocence, COVID-19 restrictions, and other constitutional claims, and denied a certificate of appealability.

Holdings

1. The one-year limitation period was triggered under 28 U.S.C. § 2244(d)(1)(A), beginning when Born's conviction became final through the conclusion of direct review or expiration of the time for seeking direct review, rather than under § 2244(d)(1)(D).
2. Born's federal habeas petition was untimely and had to be dismissed with prejudice, notwithstanding his arguments for statutory tolling, equitable tolling, actual innocence, and COVID-19-related filing restrictions.
3. A certificate of appealability was denied because Born did not make a substantial showing of the denial of a constitutional right.

Questions Presented

1. Whether the federal habeas petition was timely under the one-year limitation period in 28 U.S.C. § 2244(d)(1).
2. Whether § 2244(d)(1)(D), rather than § 2244(d)(1)(A), supplied the applicable trigger date for the limitation period.
3. Whether Born's arguments for statutory or equitable tolling, actual innocence, and COVID-19-related filing restrictions avoided dismissal as untimely.
4. Whether Born was entitled to a certificate of appealability.

Disposition

dismissed