Court: Court of Appeals for the Third Circuit; July 8, 2009; Federal Appellate Court
Gerald Teagle appeals the denial of his habeas corpus petition by the United States District Court for the Eastern District of Pennsylvania, focusing on whether he is entitled to equitable tolling of the AEDPA statute of limitations due to claims of actual innocence. The court affirms the denial, stating Teagle has not established a valid claim of actual innocence, thus not needing to decide on equitable tolling.
Teagle was convicted alongside co-defendant John Hunter for the first-degree murder of Marvin York on May 12, 1983. Both defendants admitted to shooting York but claimed self-defense, alleging he reached for a gun. However, witness Konrad Jett testified that he saw Teagle and Hunter approach York with guns drawn and fire multiple shots at close range, asserting York was unarmed at the time. Police corroborated Jett’s account by noting that no weapons were found on York or at the scene.
Teagle and Hunter contended that York had previously threatened them over drug debts and that they shot him in self-defense when they believed he was about to harm them. After being sentenced to life imprisonment on September 20, 1984, Teagle's direct appeal and subsequent postconviction relief petitions were unsuccessful, with the last state petition being dismissed as untimely in 2005, affirmed by the Pennsylvania courts.
Teagle's habeas petition, filed on July 5, 2007, included a claim based on new evidence from Jett, who allegedly indicated remorse about his trial testimony. Jett purportedly claimed that York threatened to kill Teagle and Hunter on the day of the shooting. However, the court found that Teagle did not substantiate a credible claim of actual innocence that would justify equitable tolling of the AEDPA statute.
Jett witnessed Teagle and Hunter approach York's car before shooting him and later found a gun in York's lap, which he passed to bystanders. He admitted to lying at trial to protect York's reputation but expressed anger towards Teagle and Hunter for killing his friend. Jett could not confirm if York brandished the weapon before being shot. Teagle’s habeas petition included corroborative statements from Anthony Eure and Mikal Muhammad, asserting that York had previously threatened and assaulted them, though Eure claimed his information was not utilized by Teagle's trial counsel. The District Court denied the habeas petition as time-barred under AEDPA's statute of limitations, stating Teagle was not entitled to statutory tolling since his third postconviction relief petition was deemed untimely. The court also determined that Teagle did not demonstrate actual innocence to justify equitable tolling. Though appellate jurisdiction was established under 28 U.S.C. 1291 and 2253, and a certificate of appealability was issued regarding equitable tolling related to actual innocence, the court noted that, to qualify for such tolling, Teagle needed to provide "new reliable evidence" proving it more likely than not that no reasonable juror would have convicted him. Teagle's evidence, particularly Jett's recantation, was found insufficient to satisfy this demanding standard, as recantation testimony is generally viewed with suspicion and lacks reliability. The other statements from Eure and Muhammad were not considered new evidence, as the information was already available at trial.
The three affidavits presented do not demonstrate that no reasonable juror could have found Teagle guilty beyond a reasonable doubt, despite their claims about York's violent behavior towards Teagle and Hunter prior to his death. While the affidavits support the defendants' trial testimonies, they also suggest that Teagle had motive for the murder. Jett's affidavit confirms that York was armed but does not clarify who drew a firearm first. A juror could reasonably conclude that Teagle, armed and approached by a man who had previously threatened him, was the first to act. The District Court's order denying habeas relief will be affirmed. The state court's Notes of Testimony were not included in the appendix, and the discussion of trial testimony is based on the District Court's opinion. Teagle's appeal includes a claim regarding statutory tolling under 2244(d)(2), which was not addressed since the issue fell outside the certificate of appealability. The District Court's finding that Teagle’s state postconviction relief application was untimely and therefore not 'properly filed' under 2244(d)(2) is not debatable among reasonable jurists. Teagle's second application was dismissed as untimely, and the court noted that when a petition is untimely under state law, further proceedings under 2244(d)(2) are precluded. It would have been prudent for defense counsel to file a 'protective' federal petition to stay proceedings while exhausting state remedies, especially given the timeline of Teagle's applications. The potential for equitable tolling based on claims of actual innocence exists, but defendants are still bound by statutory deadlines. Lastly, Eure indicated he informed Teagle's trial counsel about witnessing York's threatening behavior, but no follow-up occurred.
