Dwight T. Champion v. Warden Taurean James

Summary

The United States District Court for the Western District of Tennessee granted the respondent’s motion to dismiss Dwight T. Champion’s petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court held that the petition was untimely, rejected equitable tolling and the gateway actual-innocence exception, denied a certificate of appealability, and certified that an appeal would not be taken in good faith.

Holdings

1. The petition was untimely under 28 U.S.C. § 2244(d)(1)(A). The limitations period began after the time for seeking United States Supreme Court review of the Tennessee Supreme Court's denial of discretionary review expired, was statutorily tolled during the state post-conviction proceedings, resumed after those proceedings ended, and expired before Champion filed his federal petition.
2. Champion was not entitled to equitable tolling because he failed to establish both reasonable diligence in pursuing his federal habeas rights and an extraordinary circumstance that prevented timely filing.
3. Champion did not satisfy the actual-innocence gateway because he presented no new reliable evidence showing that, in light of that evidence, no reasonable juror would have convicted him.
4. A certificate of appealability was denied because Champion did not make a substantial showing of the denial of a constitutional right and no reasonable jurist could debate the court's conclusion that the petition was time barred.

Questions Presented

1. Whether Champion's § 2254 petition was barred by the one-year federal habeas statute of limitations.
2. Whether Champion was entitled to equitable tolling based on alleged lack of notice from post-conviction counsel concerning the Tennessee Supreme Court's denial of discretionary review.
3. Whether Champion satisfied the actual-innocence gateway exception to permit review of his untimely petition.
4. Whether Champion was entitled to a certificate of appealability or leave to proceed in forma pauperis on appeal.