Randy Patterson v. Blaine Lafler

BOGGS, Circuit Judge.

Randy Patterson, a Michigan prisoner convicted of arson, conspiracy, and second-degree murder, appeals the denial of his petition for a writ of habeas corpus. He argues that the United States District Court for the Eastern District of Michigan erred in holding that the suit was time-barred and not eligible for equitable tolling. We disagree, and affirm.

I

In 2005, Patterson was convicted of second-degree murder, arson of a dwelling, and conspiracy to commit arson. A jury trial was originally held on the three charges. The jury returned a guilty verdict on the arson and…