Johnson v. Bauman, No. 20-2181 (6th Cir. 2022)
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Johnson pleaded no contest in Michigan state court to drug crimes. He was sentenced as a habitual offender, at the bottom of his guidelines range. Johnson later sought state post-conviction relief, seeking to withdraw his plea because his trial counsel was ineffective, and seeking resentencing because the judge based his sentence on a fact not admitted or proved beyond a reasonable doubt. Johnson sought to compel his trial counsel to produce his case files and sit for an interview with Johnson’s new counsel. That interview apparently never took place, but Johnson secured an affidavit from his trial counsel. Johnson did not file that affidavit (or any other evidence) and did not ask for additional discovery, for a date for an evidentiary hearing, or for a ruling on his motion.
Johnson filed a federal habeas petition, acknowledging that the state court had not yet ruled on his motion but asserting that special circumstances existed due to “the inordinate delay.” The Sixth Circuit affirmed the dismissal of the petition without prejudice for failure to exhaust state remedies. Any delay was attributable to Johnson, particularly his failure to request a state court evidentiary hearing. Johnson’s case is not the extreme instance in which circumstances beyond his control left him “incapable” of remedying the constitutional violations he alleges.
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