Mcquiggin v. Perkins

569 U.S. 383 (2013)

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Nature of the Case

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Facts

P attended a party in Flint, Michigan, in the company of his friend, Rodney Henderson, and an acquaintance, Damarr Jones. The three men left the party together. Henderson was later discovered on a wooded trail, murdered by stab wounds to his head. P was charged with the murder. Jones was the key witness for the prosecution. He testified that P alone committed the murder while Jones looked on. Chauncey Vaughn, a friend of P and Henderson, testified that, prior to the murder, P had told him he would kill Henderson, and that P later called Vaughn, confessing to his commission of the crime.

P testified that he left Henderson and Jones to purchase cigarettes at a convenience store. When he exited the store, Jones and Henderson were gone. P said that he then visited his girlfriend. About an hour later, P recalled, he saw Jones standing under a streetlight with blood on his pants, shoes, and plaid coat. P was convicted of first-degree murder. The Michigan Court of Appeals affirmed the conviction and sentence, and the Michigan Supreme Court denied leave to appeal. The conviction became final on May 5, 1997. P filed his federal habeas corpus petition on June 13, 2008. P asserted newly discovered evidence of actual innocence. He relied on three affidavits, each pointing to Jones, not P, as Henderson’s murderer. The first affidavit was dated January 30, 1997. The second affidavit was dated March 16, 1999. The third affidavit was dated July 16, 2002. The District Court found the affidavits insufficient. Characterizing the affidavits as newly discovered evidence was “dubious.” It also ruled that the petition was untimely under §2244(d)(1)(D).” P had until July 16, 2003, in which to file his habeas petition. It ruled that P had not established exceptional circumstances. P had failed utterly to demonstrate the necessary diligence in exercising his rights. P appealed. The Sixth Circuit granted a certificate of appealability limited to a single question: Is reasonable diligence a precondition to relying on actual innocence as a gateway to the adjudication of a federal habeas petition on the merits? The Sixth Circuit held that P's gateway actual-innocence allegations allowed him to present his ineffective-assistance-of-counsel claim as if it were filed on time. D appealed.