Huggins v. Martel
- Yvonne Rogers
- 3:06-cv-07254
- U.S. District Court · Northern District of California
- 2
In Huggins v. Broomfield, Judge Rogers ordered an amended habeas petition within 90 days without deciding whether a new filing deadline applied.
Michael James Huggins received 90 days to file an amended habeas petition and could later request more time; the respondent was affected by the revised briefing schedule.
What happened
Michael James Huggins’s remaining habeas claims followed the Alameda County Superior Court’s December 15, 2020 vacatur of his death sentence. The parties proposed different deadlines for an amended petition.
Huggins argued that the state court’s intervening judgment restarted the federal one-year filing period and proposed a December 10, 2021 deadline. The respondent disagreed about whether that rule applied to an amendment of a pending petition but agreed to give Huggins 90 days to amend.
The court ordered that Huggins’s amended petition was due within 90 days of the order and said he could request more time later. Judge Rogers did not decide whether the state court’s action restarted the filing period.
The detailed version
- Huggins v. Martel · No. 3:06-cv-07254
- Yvonne Rogers
- May 4, 2021
Background
The parties submitted a proposed briefing schedule under an earlier court order. The schedule concerned Michael James Huggins’s remaining federal habeas claims after the Alameda County Superior Court vacated his death sentence on December 15, 2020.
Huggins proposed filing an amended petition by December 10, 2021. He argued that, under Smith v. Williams, an intervening state-court judgment restarted the one-year limitations period for federal habeas claims arising from his convictions and sentences. He asserted that the new period would expire on December 15, 2021.
The opinion explains that Smith held that an amended judgment of conviction counts as a new judgment that starts a new one-year limitations period under 28 U.S.C. § 2244(d). The respondent argued that Smith did not apply because it involved an initial petition rather than an amendment to a petition already pending. The respondent instead proposed allowing Huggins 90 days to amend, without prejudice to requesting additional extensions.
Ruling
Because the respondent agreed to an extension of time, the court said it did not need to decide whether the vacatur of Huggins’s death sentence triggered a new limitations period under Smith. The court ordered that Huggins’s amended petition was due within 90 days of May 4, 2021. It also stated that Huggins could later request an additional extension if necessary.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.