Speagle v. State of Illinois

Summary

The United States District Court for the Southern District of Illinois dismissed Billy A. Speagle’s 28 U.S.C. § 2254 habeas petition as untimely under the one-year statute of limitations in 28 U.S.C. § 2244(d). The court concluded that Speagle’s state-court judgment became final in 2013 and that later state proceedings did not make the federal petition timely. The court also denied a certificate of appealability.

Holdings

1. The petition was time-barred because Speagle's state-court judgment became final on September 21, 2013, and he did not file the federal habeas petition until April 27, 2026, well after expiration of the one-year limitations period under 28 U.S.C. § 2244(d)(1)(A).
2. Dismissal was required under Rule 4 because it plainly appeared from the petition that Speagle was not entitled to federal habeas relief.
3. A certificate of appealability was denied because Speagle did not make a substantial showing of the denial of a constitutional right and reasonable jurists would not debate the procedural ruling.

Questions Presented

1. Whether Speagle's § 2254 petition was barred by the one-year statute of limitations in 28 U.S.C. § 2244(d).
2. Whether the state post-conviction proceedings tolled the federal limitations period sufficiently to make the April 27, 2026 petition timely.
3. Whether a certificate of appealability should issue after dismissal on procedural grounds.

Disposition

dismissed