Robert Boyd v. Warden, Madison Correctional Institution

Summary

The United States District Court for the Southern District of Ohio denies Robert Boyd’s requests for production of documents in his 28 U.S.C. § 2254 habeas corpus case. The court explains that habeas discovery is governed by the Rules Governing § 2254 Proceedings, requires a showing of good cause and materiality, and is limited by Cullen v. Pinholster. The court grants Boyd’s motion for an extension of time to file his reply through December 15, 2025.

Holdings

1. A habeas petitioner is not entitled to discovery as a matter of course; discovery requires a fact-specific showing of good cause and materiality and remains within the court's discretion. Boyd failed to make that showing, so his requests for production of documents were denied.
2. In evaluating a claim under § 2254, a federal habeas court is generally limited to the record that was before the last state court to consider the claim, and may not use new evidence to assess the reasonableness of the state court's constitutional analysis.
3. Boyd was granted an extension of time through and including December 15, 2025, to file his reply or traverse.

Questions Presented

1. Whether Boyd was entitled to discovery under Rule 6 of the Rules Governing § 2254 Cases.
2. Whether Boyd had shown that the requested documents were material to resolution of his habeas claims.
3. Whether Boyd should receive an extension of time to file his reply or traverse.

Disposition

other