United States District Court, M.D. Alabama, Southern Division
RECOMMENDATION OF THE MAGISTRATE JUDGE
STEPHEN M. DOYLE UNITED STATES MAGISTRATE JUDGE.
case is before the court on a pro se petition for
writ of habeas corpus under 28 U.S.C. § 2254 filed by
state inmate Paul Mansfield. Doc. 1. Mansfield challenges his
guilty plea convictions for two counts of failing to register
as a sex offender entered against him by the Circuit Court of
Houston County, Alabama. See Docs. 8-2 & 8-5. In
March 2016, that court sentenced Mansfield to concurrent
terms of 10 years in prison. See Doc. 8-1 at 2-3;
Doc. 8-4 at 2-3. Under the Alabama Split Sentence Act, the
sentences were split, with Mansfield to serve two years in
prison concurrently with time he was serving for a Florida
conviction. See Doc. 8-1 at 3; Doc. 8-4 at 3.
Mansfield took no appeal from his Alabama convictions.
November 14, 2016, Mansfield initiated this action by filing
a § 2254 petition arguing that the State of Alabama
violated the Interstate Agreement on Detainers Act
(“IADA”) by not trying him within 180 days after
he demanded a final disposition in October
2014. Doc. 1 at 5 & 16-18.
filed an answer in which they contend that the claim in
Mansfield's § 2254 petition is procedurally
defaulted because Mansfield failed to present the claim to
the state courts in accordance with the State's
procedural rules. Doc. 8 at 6-8.
took advantage of the opportunity granted him to respond to
Respondents' answer. See Docs. 9 & 10. After
reviewing the § 2254 petition, Respondents' answer,
and Mansfield's response, the court concludes that no
evidentiary hearing is required and that Mansfield's
petition is due to be denied under the provisions of Rule
8(a), Rules Governing Section 2254 Cases in the United
States District Courts.
procedural default doctrine ensures that “state courts
have had the first opportunity to hear the claim sought to be
vindicated in a federal habeas proceeding.” Picard
v. Connor, 404 U.S. 270, 276 (1971). Before a §
2254 petitioner may obtain federal habeas corpus review, he
must “exhaust” his federal claims by raising them
in the appropriate court, giving the state courts an
opportunity to decide the merits of the constitutional issue
raised. See 28 U.S.C. § 2254(b)(1) & (c);
Duncan v. Walker, 533 U.S. 167, 178-79 (2001). To
exhaust a claim fully, a petitioner must “invok[e] one
complete round of the State's established appellate
review process.” O'Sullivan v. Boerckel,
526 U.S. 838, 845 (1999).
Alabama, a complete round of the established appellate review
process includes an appeal to the Alabama Court of Criminal
Appeals, an application for rehearing to that court, and a
petition for discretionary review-a petition for a writ of
certiorari-filed in the Alabama Supreme Court. See Smith
v. Jones, 256 F.3d 1135, 1140-41 (11th Cir. 2001);
Ala.R.App.P. 39 & 40 The exhaustion requirement applies
to state post-conviction proceedings and to direct appeals.
See Pruitt v. Jones, 348 F.3d 1355, 1359 (11th Cir.
claims not properly exhausted in the state courts are
procedurally defaulted if presentation of the claims in state
court would be barred by state procedural rules. Gray v.
Netherland, 518 U.S. 152, 161-62 (1996); Coleman v.
Thompson, 501 U.S. 722, 735 n.1 (1991). “[I]f the
petitioner failed to exhaust state remedies and the court to
which the petitioner would be required to present his claims
in order to meet the exhaustion requirement would now find
the claims procedurally barred[, ] . . . there is a
procedural default for purposes of federal habeas.”
Coleman, 501 U.S. at 735 n.1 (citations omitted);
see Henderson v. Campbell, 353 F.3d 880, 891 (11th
Mansfield's Claim is Procedurally Defaulted.
contends that the State of Alabama violated the IADA by
failing to try him within 180 days after he demanded a final
disposition of his case in October 2014. Doc. 1 at 5 &
16-18. Respondents assert that Mansfield has procedurally
defaulted his claim. Doc. 8 at 6-8. Specifically, Respondents
argue that the claim was not exhausted in the state courts in
accordance with the State's procedural rules and that the
claim is not capable of further presentation to the state
courts due to state procedural rules. Id.
record reflects that Mansfield raised his IADA claim in a
pretrial motion to lift detainer and to dismiss the
indictment filed in July 2015. Doc. 8-7. The trial court
denied Mansfield's motion on grounds that the State never
received the demand for final disposition that Mansfield
claimed to have filed in October 2014 and thus Mansfield
failed to properly invoke the IADA. Doc. 8-9. When later
pleading guilty, Mansfield did not reserve his IADA claim for
review on appeal. Further, Mansfield took no appeal from his
conviction. Under the circumstances, it is clear that
Mansfield failed to ...