Shawn Burton v. Superintendent, SCI Forest, et al.

Summary

The United States District Court for the Western District of Pennsylvania addresses Shawn Burton’s counseled amended petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court dismisses the claims with prejudice under 28 U.S.C. § 2244(b)(4) and denies a certificate of appealability. The opinion discusses Burton’s first-degree murder conviction, successive collateral proceedings, and claims involving alleged new evidence, recantations, Brady, and Napue violations.

Holdings

1. The claims are barred by Teague because the proposed due process rule was not dictated by precedent when Burton's conviction became final and would constitute a novel procedural rule applied retroactively on collateral review.
2. Burton's freestanding actual-innocence claim was not sufficiently grounded in established constitutional precedent to be cognizable on federal habeas review and was barred by Teague.
3. The remaining Napue claims did not satisfy § 2244(b)(2)(B)(ii) because Burton failed to establish by clear and convincing evidence that, viewing the evidence as a whole, no reasonable factfinder would have found him guilty but for the alleged constitutional error.
4. A certificate of appealability was denied because reasonable jurists would not debate the dismissal of Burton's claims or the procedural basis for dismissal.

Questions Presented

1. Whether Burton's Napue-based claims alleging that the prosecution presented or failed to correct false trial testimony satisfied 28 U.S.C. § 2244(b)(2)(B)(ii).
2. Whether Burton's proposed due process theory—that the prosecution violated due process by failing to correct allegedly false testimony learned of during post-conviction proceedings—was barred as a novel, nonretroactive rule under Teague v. Lane.
3. Whether Burton's freestanding actual-innocence claim was cognizable in federal habeas and could satisfy § 2244(b)(2)(B)(ii).
4. Whether the state PCRA court's findings that Goodwine's confessions and O'Toole's alleged admission were unreliable were rebutted by clear and convincing evidence.
5. Whether Burton was entitled to a certificate of appealability.

Disposition

dismissed