Abernathy v. Adams

CourtDistrict Court, E.D. Missouri
DecidedSeptember 30, 2025
Docket4:24-cv-01286
StatusUnknown

This text of Abernathy v. Adams (Abernathy v. Adams) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abernathy v. Adams, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

RANDALL ABERNATHY, ) ) Petitioner, ) ) ) v. ) Case No. 4:24-CV-01286-SPM ) RICHARD ADAMS, ) ) Respondent. )

MEMORANDUM OPINION This matter is before the Court on the petition of Missouri state prisoner Randall Abernathy (“Petitioner”) for a writ of habeas corpus pursuant to 28 U.S.C. § 2254 (ECF No. 1) and Petitioner’s Motion for Request for an Evidentiary Hearing (ECF No. 5). The parties have consented to the jurisdiction of the undersigned United States Magistrate Judge pursuant to 28 U.S.C. § 636(c)(1). ECF No. 17. For the following reasons, the petition and the motion will be denied. I. FACTUAL BACKGROUND The Circuit Court of St. Francois County, Missouri summarized the facts of Petitioner’s case as follows: Petitioner, Randall Paul Abernathy, serves an aggregate 125-year Missouri sentence in the Eastern Reception Diagnostic Correctional Center in St. Francois County, Missouri, where Respondent Richard Adams is the Warden, for two counts of sexual exploitation of a minor child, promoting child pornography in the first degree, first degree statutory sodomy on a child under age twelve, and tampering with physical evidence in a felony prosecution. Petitioner also serves concurrent federal sentences for production of child pornography and transportation of child pornography. Petitioner pleaded guilty in the Circuit Court of Warren County to two counts of the Class A felony of sexual exploitation of a child for which he received consecutive thirty-year sentences. He also pleaded guilty to the Class B felony promoting child pornography in the first degree for which he received a consecutive fifteen-year sentence. He also pleaded guilty to the unclassified dangerous felony of first-degree statutory sodomy of a child under age twelve for which he received a consecutive fifty-year sentence. Petitioner also pleaded guilty to and received a concurrent four-year sentence for the Class D felony of tampering with physical evidence in a felony case.

Resp’t Ex. 11, at 1.1 Petitioner did not directly appeal his guilty plea.

In his amended motion for post-conviction relief, filed pursuant to Mo. Sup. Ct. R. 29.15, Petitioner through counsel asserted three claims: (1) defense counsel assured Petitioner that he would receive less time than he actually received when he made an open guilty plea; (2) defense counsel unreasonably failed to advise Petitioner that multiple convictions for first-degree child exploitation would violate double jeopardy; and (3) no factual basis existed for the plea on Count II. Resp’t Ex. 11, at 2. The motion court denied all of these claims after an evidentiary hearing. Resp’t Ex. 4 at 5–10. On appeal, Petitioner raised only the claim that plea counsel was ineffective for failing to advise him of a possible double jeopardy violation. Resp’t Ex. 7, at 5–7. The Court of Appeals rejected this claim. Id. In his state petition for habeas corpus relief, filed pursuant to Mo. Sup. Ct. R. 91, Petitioner asserted three claims pro se: (1) that the trial court deprived Petitioner of due process by not sua sponte ordering a mental examination for Petitioner; (2) that his fifty-year sentence for statutory sodomy exceeded the maximum sentence for statutory sodomy, which he described as a Class A felony; and (3) that he received ineffective assistance of plea counsel based on the failure to request a competency evaluation. Resp’t Ex. 11, at 3. The state court denied all three claims. Resp’t Ex.

1 This document contains multiple sets of page numbers. The Court refers to the pagination in the lower right-hand corner. Additional facts relevant to Petitioner’s specific claims will be set forth in the discussion section below. 11, at 1–5. Petitioner brought these same claims in a pro se petition for habeas corpus relief in the Missouri Court of Appeals Eastern District, and the appellate court denied the petition without discussion. Resp’t Ex. 13, 14. Petitioner brought these same claims in a pro se petition for habeas corpus relief in the Missouri Supreme Court, and the Missouri Supreme Court summarily denied

the petition. Resp’t Ex. 16, 18. In the instant petition, Petitioner asserts four grounds for relief: (1) that he received ineffective assistance of plea counsel based on the failure to request a competency evaluation; (2) that Petitioner received ineffective assistance of post-conviction counsel based on the failure to request a mental competency examination of him before he was convicted and sentenced; (3) that the trial court deprived Petitioner of due process by not sua sponte ordering a mental competence examination for Petitioner; and (4) that the Missouri habeas courts erred in not granting Petitioner’s ineffective assistance of counsel claims. Pet’n, ECF No. 1.2 Respondent argues that the petition should be denied because it was not timely filed under AEDPA’s 1-year statute of limitations, 28 U.S.C. § 2244(d)(l)(A), and because each of Petitioner’s

claims has been procedurally defaulted and/or is meritless. After review, it appears to the Court that the timeliness issue is substantially more complicated than the merits and procedural default issues.3 Thus, in the interest of judicial economy, the Court will proceed to address the merits and

2 Attached to the form § 2254 petition, Petitioner included a 69-page document, restating his grounds for relief and providing “Suggestions in Support” of granting him a writ of habeas corpus. ECF No. 1-1. The Court will treat this attachment, and all others, as part of the pleadings. See Fed. R. Civ. P. 10(c) (“A copy of a written instrument that is an exhibit to a pleading is part of the pleading for all purposes”). He also attached 230 pages of exhibits which appear to be mostly state court filings and documents. ECF No. 1-2.

3 The one-year limitations period set forth in the AEDPA may be equitably tolled if a petitioner demonstrates: (1) he has been diligently pursuing his rights; and (2) an extraordinary circumstance stood in his way and prevented timely filing. Holland v. Florida, 560 U.S. 631, 649 (2010); Muhammad v. U.S., 735 F.3d 812, 815 (8th Cir. 2013). Petitioner argues that equitable tolling procedural default issues. See White v. Steele, 853 F.3d 486, 490 (8th Cir. 2017) (“[E]ven where we have reason to doubt compliance with the statute of limitations, we may proceed to the merits in the interest of judicial economy.”); Trussell v. Bowersox, 447 F.3d 588, 590-91 (8th Cir. 2006) (“[B]ecause neither the statute of limitations nor procedural default constitutes a jurisdictional bar

to our review, Day v. McDonough, 547 U.S. 198 (2006), we shall, in the interest of judicial economy, proceed to the merits of [the] petition.”). II. LEGAL STANDARDS A. Legal Standard for Reviewing Claims on the Merits Where a claim has been adjudicated on the merits in state court proceedings, a federal court may grant habeas relief only if the state court’s adjudication of the claim “(1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” 28 U.S.C.

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Abernathy v. Adams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abernathy-v-adams-moed-2025.