Tamar Jackson v. Terry Tuggle, Warden

Summary

The United States District Court for the Northern District of Oklahoma dismissed Tamar Jackson’s 28 U.S.C. § 2254 habeas petition as barred by the AEDPA statute of limitations. The court rejected Jackson’s arguments for statutory tolling, equitable tolling, and the actual-innocence gateway, denied a certificate of appealability, and substituted Terry Tuggle for Derrick Yazel as respondent.

Holdings

1. Because Jackson did not timely move to withdraw his guilty plea, his Oklahoma conviction became final ten days after entry of judgment and sentence. The one-year AEDPA limitations period therefore expired on February 13, 2017, rendering his July 14, 2025 petition untimely.
2. Jackson was not entitled to equitable tolling because he failed to show extraordinary circumstances beyond his control and failed to demonstrate that he diligently pursued his federal claims.
3. Jackson did not establish actual innocence sufficient to overcome the AEDPA limitations bar because he presented no new reliable evidence and asserted, at most, legal innocence rather than factual innocence.

Questions Presented

1. Whether Jackson's § 2254 petition was timely under the one-year statute of limitations in 28 U.S.C. § 2244(d)(1)(A).
2. Whether Jackson was entitled to statutory tolling based on his post-2017 state-court filings.
3. Whether equitable tolling applied based on alleged ineffective assistance, prosecutorial misconduct, lack of access to charging documents, or ignorance of the law.
4. Whether Jackson's actual-innocence allegations satisfied the gateway exception to the AEDPA limitations bar.

Disposition

dismissed