Aviles v. Kowalski

CourtDistrict Court, D. Montana
DecidedFebruary 28, 2024
Docket4:23-cv-00042
StatusUnknown

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

Bluebook
Aviles v. Kowalski, (D. Mont. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA GREAT FALLS DIVISION

WAYNE AVILES, Cause No. CV 23-42-GF-BMM

Petitioner, ORDER vs.

WARDEN PETE BLUDWORTH,1 ATTORNEY GENERAL OF THE STATE OF MONTANA,

Respondents.

State pro se petitioner Wayne Aviles (“Aviles”) filed an application under 28 U.S.C. § 2254, seeking habeas corpus relief. (Doc. 1.) The petition was deemed filed on June 20, 2023. (Doc. 1-4 at 1.) Aviles was subsequently ordered to show cause as to why his petition should not be dismissed as time-barred and procedurally defaulted and was advised of the relevant legal standards. (See Doc. 8.) Aviles’s double jeopardy claim was also dismissed. (Id. at 6-8.) Aviles timely responded to the Court’s order. (Doc. 9.) For the reasons discussed herein, Aviles’s petition will be dismissed.

1 While this matter has been pending, Aviles was transferred to Crossroads Correctional Center (“CCC”). See (Doc. 10.) Pursuant to Rule 2(a) of the Rules Governing Section 2254 Cases, a state prisoner seeking federal habeas relief must name as respondent the person having custody of him. See Magwood v. Patterson, 561 U.S. 320, 333 (2010). Accordingly, the docket will be updated to reflect CCC Warden Pete Bludworth as his current custodian. I. Background/Aviles’s Claims The Court previously outlined Aviles’s state court proceedings in detail.

(See Doc. 8 at 2-6.) They are summarized briefly herein. Following a plea of guilty in Montana’s Tenth Judicial District Court, Fergus County, Aviles was convicted of one count of Sexual Intercourse without Consent. (Doc. 1 at 1.) On

October 10, 2017, Aviles was sentenced to Montana Department of Corrections (“DOC”) for 10-years with none of the time suspended. See Judg. (Doc. 1 at 56- 67.) The State of Montana then notified the Montana state district court that a 10- year commitment to the DOC was unlawful under MCA § 46-18-201(3)(a)(iv)(A).

This statute provides that while an offender may be sentenced to the DOC, all but the first 5 years of the commitment must be suspended. On January 4, 2018, The Montana state district court resentenced Aviles to a 10-year commitment to the

DOC with 5-years suspended. See Amd. Judg. (Doc. 1 at 68-79.) Aviles did not file a direct appeal from either the original or amended judgment. (Id. at 3.) On August 12, 2019, Aviles filed a petition for writ of habeas corpus and supporting brief in the Montana state district court. (See Doc. 1-1 at 17-37.) There

he alleged various defects in his underlying state court proceedings. On November 21, 2022, the Montana state district court dismissed the matter. (Id. at 45-46.) The State of Montana filed a petition to revoke Aviles’s sentence while the

collateral review proceedings were pending in the Montana state district court. On May 24, 2022, the Montana state district court revoked Aviles’s suspended sentence based upon his admissions to violations. The Montana state district court

imposed a 5-year unsuspended term and awarded Aviles credit for time served and street time. Aviles did not appeal his revocation sentence. See Aviles v. Kowalski, No. OP 23-0116, Ord. at *1 (Mont. March 7, 2023).

Aviles then filed a petition for writ of habeas corpus with the Montana Supreme Court in which he contended that the sentence imposed upon revocation violated his right to be free of double jeopardy, along with fifteen additional claimed violations and constitutional infirmities, including conflict of interest and

ineffective assistance of counsel. Id. The Montana Supreme Court determined the revocation sentence was lawful and that Aviles’s right to be free of double jeopardy was not violated by revoking the suspended sentence. Id. at *2. The

Montana Supreme Court then determined Aviles’s remaining claims could not be addressed in habeas corpus, pursuant to MCA § 46-22-101(1). The claims should have been raised, if at all, on direct appeal, but Aviles was now time-barred from challenging his conviction and sentence on appeal. Id., citing MCA § 46-22-

101(2). Aviles was also advised that Montana law barred him from challenging a sentence imposed upon revocation via the remedy of habeas corpus. Id. Aviles’s petition was denied and dismissed.

Aviles filed a subsequent petition for writ of habeas corpus with the Montana Supreme Court alleging his sentence violated his right to be free from double jeopardy, along with six other claims. See Aviles v. Kowalski, No. OP 23-

0348, Ord. (Mont. July 11, 2023). The Montana Supreme Court again explained that Aviles could not raise his claims through a remedy of habeas corpus. Id. at *2. Aviles failed to file a direct appeal of his original sentence in 2017 or his

revocation sentence in 2022. This failure barred Aviles from challenging the conviction via habeas. Id. Because his claims were procedurally barred under the writ and improperly raised under state law, the petition was denied and dismissed. Id., citing MCA § 46-22-101(2).

Aviles has three claims remaining in his federal petition. He asserts: (i) Montana state district Judge Jon A. Oldenburg was biased and operated under a conflict of interest because he was a guardian ad litem for Aviles as a youth and

should have recused himself, (Doc. 1 at 9); (ii) Fred Snodgrass and Ashley Ann Harada provided ineffective assistance of counsel during the underlying criminal proceedings and sentencing when they failed to challenge the information and/or waiver of indictment, failed to provide a list of witnesses to assist in Aviles’s

defense, failed to move to strike witnesses at the conclusion of testimony, failed to object to sentencing enhancements, failed to mount objections at the time of trial, and failed to object to the presentence investigation report, (id. at 15); and (iii)

False DNA testing was used as evidence against Aviles, and he is actually innocent. (Id. at 19). II. Analysis

As a preliminary matter, this Court notes that Aviles makes no challenge to nature of his guilty plea. For example, he does not argue the plea was entered under duress or upon faulty advice of counsel. See e.g., sent. trans. (Doc. 1 at 49-

50) (Aviles admitted guilt and accepted full responsibility for committing Sexual Intercourse without Consent). The Court presumes Aviles entered the plea knowingly, voluntarily, and intelligently. A valid guilty plea forecloses a defendant from raising non-jurisdictional

defects. “When a criminal defendant has solemnly admitted in open court that he is in fact guilty of the offense with which he is charged, he may not thereafter raise independent claims relating to the deprivation of constitutional rights that occurred

prior to the entry of the guilty plea.” Tollett v. Henderson, 411 U.S. 258, 267 (1973); see also United States v. Caperell, 938 F. 2d 975, 977(9th Cir. 1991) (a guilty plea generally waives all claims of a constitutional nature occurring before the plea.) “A plea of guilty and the ensuing conviction comprehend all of the

factual and legal elements necessary to sustain a binding, final judgment of guilty and a lawful sentence.” United States v. Broce, 488 U.S. 563, 569 (1989). Accordingly, a defendant convicted after a plea is limited to challenging “whether

the underling plea was both counseled and voluntary” or whether “on the face of the record the court had no power to enter the conviction or impose the sentence. Broce, 488 U.S. at 569. The non-jurisdictional claims Aviles presents are not

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Aviles v. Kowalski, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aviles-v-kowalski-mtd-2024.