Adams v. Garrett

CourtDistrict Court, D. Nevada
DecidedFebruary 26, 2025
Docket3:22-cv-00480
StatusUnknown

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

Bluebook
Adams v. Garrett, (D. Nev. 2025).

Opinion

1 2 3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 * * * 6 EDWARD ADAMS, Case No. 3:22-cv-00480-MMD-CSD

7 Petitioner, ORDER

8 v. 9 GARRETT, et al., 10 Respondents. 11 12 I. SUMMARY 13 28 U.S.C. § 2254 habeas corpus Petitioner Edward Adams challenges his 14 conviction of numerous counts, including sexual assault of a minor and kidnapping, for 15 which he received a lengthy sentence. (ECF No. 31.) His claims include that his trial 16 counsel rendered ineffective assistance in several ways and that the State engaged in 17 prosecutorial misconduct during his trial. Respondents filed a Motion to Dismiss, arguing 18 that several claims are untimely, unexhausted, procedurally barred, and/or not 19 cognizable. (ECF No. 35 (“Respondents’ Motion”).) Adams then filed a Motion for Stay 20 and Abeyance. (ECF No. 42 (“Petitioner’s Motion”).) As discussed below, the Court grants 21 Petitioner’s Motion and denies Respondents’ Motion without prejudice. 22 II. BACKGROUND 23 In November 2009, an Eighth Judicial District (Clark County, Nevada) jury 24 convicted Adams of first-degree kidnapping, battery with the intent to commit sexual 25 assault, seven counts of sexual assault, and one count of open or gross lewdness. (Exh. 26 27.)1 The state district court sentenced him to terms amounting to 80 years to life. (Exh. 27 1 29.) The Nevada Supreme Court affirmed his convictions in July 2012, and the Nevada 2 Court of Appeals affirmed the denial of his state postconviction habeas corpus petition in 3 September 2022. (Exhs. 60, 121.) 4 Adams dispatched his original, pro se habeas petition in October 2022. (ECF No. 5 6.) Because it appeared that at least some of his legal claims may be complex, the Court 6 granted his motion for counsel and appointed the Federal Public Defender (“FPD”). 7 Adams ultimately filed a second-amended petition through the FPD, containing the 8 following claims: 9 Ground 1: The State committed prosecutorial misconduct during 10 closing arguments in violation of Adams’ Fifth, Sixth, and Fourteenth Amendment rights. 11

12 Ground 2: The evidence was insufficient to convict Adams of multiple counts of sexual assault and open or gross lewdness because 13 multiple convictions for one continuous act violated his Fifth, Sixth, and Fourteenth Amendment rights. 14

15 Ground 3: Insufficient evidence was presented to convict Adams of battery with intent to commit sexual assault in violation of his Fifth, 16 Sixth, and Fourteenth Amendment rights.

17 Ground 4: The district court allowed the prosecution to show the jury prejudicial photographs of Adams in jail clothing during opening 18 statements and closing argument in violation of his Fifth, Sixth, and 19 Fourteenth Amendment rights.

20 Ground 5: Trial counsel was ineffective in violation of Adams’ Fifth, Sixth, and Fourteenth Amendment rights for failing: 21 A. To remove Juror No. 7 from the jury panel after she disclosed a 22 social relationship with the judge and one of the investigating 23 officers; B. To challenge the sufficiency of the evidence to support multiple 24 convictions for the redundant and duplicative sexual assault and open or gross lewdness count; 25 C. To challenge the jury instruction that allowed jurors to find that one sexual encounter constituted multiple separate criminal 26 counts; 27 D. To challenge the sufficiency of the evidence to support a conviction for battery with intent to commit sexual assault; E. To adequately communicate with Adams prior to trial and for 1 failing to prepare for trial; F. To challenge the expert testimony of Amy Coe; 2 G. To object to the State’s prejudicial PowerPoint slides during 3 closing arguments; H. To seek a mistral due to the prosecutor’s misconduct during 4 closing arguments; I. To present compelling mitigation evidence at sentencing; and 5 J. Trial counsel’s cumulative errors prejudiced Adams. 6 7 (ECF No. 31.) 8 Respondents then moved to dismiss, arguing that grounds 3, 4, and 5(B)-(J) are 9 untimely, unexhausted, procedurally barred, and/or not cognizable. (ECF No. 35.) In 10 response, Adams has moved for a stay and abeyance. (ECF No. 42.) He states that he 11 has filed a state postconviction petition raising most of the claims in the second-amended 12 petition and that he can overcome the state procedural bars because he is actually 13 innocent of sexual assault.2 He also asserts that some of his claims rely on new evidence 14 that he was unable to develop during his state court proceedings on his first state 15 postconviction habeas petition. 16 III. DISCUSSION 17 Federal courts may not grant a writ of habeas corpus brought by a person in 18 custody pursuant to a state court judgment unless “the applicant has exhausted the 19 remedies available in the courts of the State.” 28 U.S.C. § 2254(b)(1)(A). This exhaustion 20 requirement is “grounded in principles of comity” as it gives states “the first opportunity to 21 address and correct alleged violations of state prisoner’s federal rights.” Coleman v. 22 Thompson, 501 U.S. 722, 731 (1991). In general, a federal district court must dismiss an 23 unexhausted petition without prejudice. See id. (noting that the Supreme Court “has long 24 held that a state prisoner’s federal habeas petition should be dismissed if the prisoner 25 has not exhausted available state remedies as to any of his federal claims”); Castille v. 26 Peoples, 489 U.S. 346, 349 (1989) (habeas petitions should be dismissed if state 27 remedies have not been exhausted as to any federal claims). 1 A district court is authorized to stay an unexhausted petition in “limited 2 circumstances,” to allow a petitioner to present unexhausted claims to the state court 3 without losing his right to federal habeas review due to the relevant one-year statute of 4 limitations. See Rhines v. Weber, 544 U.S. 269, 273-75 (2005); Mena v. Long, 813 F.3d 5 907, 912 (9th Cir. 2016) (holding that district courts have authority to stay and hold in 6 abeyance both mixed petitions and “fully unexhausted petitions under the circumstances 7 set forth in Rhines”). Under the Rhines test, “a district court must stay a mixed petition 8 only if: (1) the petitioner has ‘good cause’ for his failure to exhaust his claims in state 9 court; (2) the unexhausted claims are potentially meritorious; and (3) there is no indication 10 that the petitioner intentionally engaged in dilatory litigation tactics.” Wooten v. Kirkland, 11 540 F.3d 1019, 1023 (9th Cir. 2008) (citing Rhines, 544 U.S. at 278). 12 The Ninth Circuit has acknowledged that the Rhines “good cause” standard does 13 not require “extraordinary circumstances.” Id. at 1024 (citing Jackson v. Roe, 425 F.3d 14 654, 661-62 (9th Cir. 2005)). But courts “must interpret whether a petitioner has ‘good 15 cause’ for a failure to exhaust in light of the Supreme Court’s instruction in Rhines that 16 the district court should only stay mixed petitions in ‘limited circumstances.’” Id. (citing 17 Jackson, 425 F.3d at 661). Courts must also “be mindful that AEDPA aims to encourage 18 the finality of sentences and to encourage petitioners to exhaust their claims in state court 19 before filing in federal court.” Id. (citing Rhines, 544 U.S. at 276-77). 20 Courts in this district have declined to prescribe the strictest possible standard for 21 issuance of a stay. See, e.g., Riner v. Crawford, 415 F. Supp.

Related

Castille v. Peoples
489 U.S. 346 (Supreme Court, 1989)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
United States v. Rodriguez-Casiano
425 F.3d 12 (First Circuit, 2005)
Lee v. Lampert
653 F.3d 929 (Ninth Circuit, 2011)
Wooten v. Kirkland
540 F.3d 1019 (Ninth Circuit, 2008)
Riner v. Crawford
415 F. Supp. 2d 1207 (D. Nevada, 2006)
Colon-Marrero v. Garcia-Velez
813 F.3d 1 (First Circuit, 2016)
Shinn v. Martinez Ramirez
596 U.S. 366 (Supreme Court, 2022)

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