The following excerpt is from Broxton v. Arnold, No. 2: 16-cv-1548 GEB KJN P (E.D. Cal. 2017):
For the reasons discussed above, the undersigned finds that petitioner has not made a non-frivolous showing that he had a severe mental impairment during the filing period that made it impossible for him to file a timely federal habeas petition. Even without access to his mental health records, petitioner should be able to describe his mental illness and how it impacted his ability to file his state and federal petitions. Accordingly, petitioner is not entitled to equitable tolling based on his alleged mental illness.
V. Martinez v. Ryan
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