Wallace v. Superintendent Mahanoy SCI, No. 18-3006 (3d Cir. 2021)
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For much of his life, Wallace has suffered from severe mental illness, including bipolar disorder with psychotic features, chronic depression, ADHD, and major affective disorder. On February 28, 2000, Wallace, during a severe psychotic episode, got into bed with his wife, Eileen, and used the knife to stab Eileen to death. Wallace then dressed, stowed the knife in a drawer, and locked the house, leaving Eileen’s body behind. Wallace took a train to Philadelphia where he planned to commit suicide. Police were waiting for him; his mother had disclosed his whereabouts. Wallace admitted to stabbing Eileen, acting on a belief that death would set her spirit free. Wallace pleaded guilty but mentally ill to third-degree murder and related crimes. He missed the January 2002 deadline for a federal habeas corpus petition and filed in September 2015, arguing that his mental illness so hampered his ability to think clearly that he could not reasonably have been expected to file earlier.
The Third Circuit affirmed the dismissal of the petition, concluding that Wallace was not entitled to equitable tolling to extend the filing deadline. Although Wallace claimed that his prescribed use of the drug Ritalin may have exacerbated his psychosis, rendering him involuntarily intoxicated or legally insane at the time of his crime such that he could not form the mens rea necessary for murder, the court declined to employ the “actual innocence gateway,” to excuse him from the deadline.
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