Sanchez-Rengifo v. J. Caraway, No. 14-2876 (7th Cir. 2015)
Annotate this CaseBased on his forcible rape of a 15-year-old, Rengifo was convicted of three counts of first-degree child sexual abuse while armed and one count of second-degree child sexual abuse while armed. After exhausting state remedies, he brought a federal petition for a writ of habeas corpus under 28 U.S.C. 2241. The district court denied the petition and did not address the matter of a certificate of appealability. Rengifo filed an appeal. The Seventh Circuit dismissed for lack of jurisdiction. For purposes of habeas corpus relief, Rengifo’s petition must be deemed as seeking relief from a detention “aris[ing] out of process issued by a State court,” 28 U.S.C. 2253(c)(1)(A). A certificate of appealability is therefore required before he can pursue an appeal, but a certificate of appealability cannot be granted. Because the legislature defined the unit of punishment as each act of child sexual abuse, Rengifo did not suffer multiple punishments for the same crime, so his sentences did not run afoul of the Double Jeopardy Clause and he raised no substantial constitutional question that could serve as a predicate for a certificate of appealability.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.