Billie Joe Chapman v. Demetric Godfrey, Warden

Summary

The United States District Court for the Western District of Tennessee denies Billie Joe Chapman’s motions to appoint counsel and recuse the judge, construes his amended petition as a motion to amend, and denies leave to amend. The Court also denies Chapman’s 28 U.S.C. § 2254 petition challenging the voluntariness of his guilty plea and alleged forced administration of medication, concluding that the claims do not warrant habeas relief. The Court denies a certificate of appealability and leave to appeal in forma pauperis and certifies that an appeal would not be taken in good faith.

Holdings

1. Chapman was not entitled to habeas relief because the state courts reasonably determined, based on the plea colloquy and evidentiary record, that his guilty plea was knowing, intelligent, and voluntary.
2. Chapman procedurally defaulted his claim concerning forced hospitalization, civil commitment, and medication because he did not fairly present that claim through the Tennessee appellate review process and showed neither cause and prejudice nor actual innocence.
3. The forced-hospitalization and medication claim was not cognizable under § 2254 because it did not challenge custody pursuant to the criminal judgment; any challenge to a completed period of civil commitment was also moot.
4. Leave to amend was denied because the proposed new habeas claims were untimely, did not relate back to the original petition, and amendment therefore would be futile.
5. The motion to recuse was denied because Chapman alleged no facts that would cause a reasonable, objective person to question the judge’s impartiality.

Questions Presented

1. Whether Chapman’s guilty-plea voluntariness claim warranted federal habeas relief under AEDPA.
2. Whether Chapman’s claim concerning forced hospitalization, civil commitment, and medication was procedurally defaulted.
3. Whether the forced-hospitalization and medication claim was cognizable under 28 U.S.C. § 2254 or moot because it did not challenge the custody imposed by the criminal judgment.
4. Whether leave to amend should be granted for new habeas claims raised after the limitations period.
5. Whether the district judge should recuse based on alleged familial relationship, bias, and prior rulings.
6. Whether counsel should be appointed because Chapman alleged mental disability.

Disposition

denied