United States District Court, M.D. Alabama, Northern Division
RECOMMENDATION OF THE MAGISTRATE JUDGE
WALLACE CAPEL, Jr., Magistrate Judge.
This case is before the court on a petition for writ of habeas corpus under 28 U.S.C. § 2254 filed by Alabama inmate Christopher Chappell ("Chappell") on April 29, 2015. Doc. No. 1. Chappell challenges his 1984 guilty plea convictions and resulting life sentence for first-degree rape, first-degree burglary, and second-degree burglary. The respondents argue that Chappell's petition is time-barred by the one-year limitation period applicable to § 2254 petitions, as set forth in 28 U.S.C. § 2244(d). Doc. No. 8. After reviewing the pleadings, evidentiary materials, and applicable law, the court finds that no evidentiary hearing is required and that the § 2254 petition should be denied as untimely.
The AEDPA's One-Year Limitation Period
Title 28 U.S.C. § 2244(d) of the Antiterrorism and Effective Death Penalty Act of 1996 ("AEDPA") provides the statute of limitations for federal habeas petitions and states:
(1) A 1-year period of limitation shall apply to an application for a writ of habeas corpus by a person in custody pursuant to the judgment of a State court. The limitation period shall run from the latest of -
(A) the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review;
(B) the date on which the impediment to filing an application created by State action in violation of the Constitution or laws of the United States is removed, if the applicant was prevented from filing by such State action;
(C) the date on which the constitutional right asserted was initially recognized by the Supreme Court, if the right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review; or
(D) the date on which the factual predicate of the claim or claims presented could have been discovered through the exercise of due diligence.
(2) The time during which a properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim is pending shall not be counted toward any period of limitation under this subsection.
28 U.S.C. § 2244(d).
On April 11, 1984, Chappell pled guilty in the Circuit Court of Montgomery County to first-degree rape, first-degree burglary, and second-degree burglary. See Doc. No. 1 at 1; Doc. No. 1-1 at 1-2. On that same date, the trial court imposed a ...