Case Explained: Donaldson v. Langford

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-08-04 Docket: 5:24-CV-03108-JWL) The tenth-circuit denied the petitioner’s request for a certificate of appealability and dismissed his appeal from the district court’s dismissal of his 28 U.S.C. § 2254 habeas petition with prejudice. The court applied the standard under *Slack v. McDaniel*, determining that reasonable jurists could not debate the correctness of the district court’s procedural rulings. The district court had found that all of the petitioner’s claims were barred by anticipatory or actual procedural default because they were either unexhausted in state court or dismissed under adequate and independent state procedural rules. The appellate court concluded that the petitioner failed to demonstrate cause for the defaults, as he did not present an independent ineffective assistance of counsel claim to the state courts to excuse his failure to raise claims there. Additionally, the court held that the petitioner failed to satisfy the fundamental miscarriage of justice exception because his allegations of factual innocence were unsupported by new, reliable evidence in the record. Consequently, the appeal is dismissed without a certificate of appealability. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.