Ayer v. NHSP Warden

2014 DNH 087
CourtDistrict Court, D. New Hampshire
DecidedApril 25, 2014
Docket07-cv-304-SM
StatusPublished

This text of 2014 DNH 087 (Ayer v. NHSP Warden) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ayer v. NHSP Warden, 2014 DNH 087 (D.N.H. 2014).

Opinion

Ayer v. NHSP Warden 07-CV-304-SM 4/25/14 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Daniel E. Ayer, Sr.

v. Case No. 07-cv-304-SM Opinion No. 2014 DNH 087 Richard M. Gerry, Warden, New Hampshire State Prison

O R D E R

Daniel Ayer filed a petition for a writ of habeas corpus

(doc. no. 1) in this court, pursuant to 28 U.S.C. § 2254, on

September 26, 2007. This matter is before the court for

preliminary review pursuant to Rule 4 of the Rules Governing

Section 2254 Cases in the United States District Courts, and for

a ruling on pending motions.

Background

Shortly after Ayer filed the initial habeas petition (doc.

no. 1) in this matter, the magistrate judge issued a report and

recommendation (doc. no. 8) identifying and numbering ten claims

for relief (with subparts), recommending the dismissal of claim

4, finding that claims 1, 3-7, 9, and 10 had been properly

exhausted and were ready to proceed, and further finding that

Ayer had not demonstrated that claims 2(a) – 2(h), all asserting

that Ayer’s trial counsel was ineffective, had been exhausted.

Simultaneously with the report and recommendation (doc. no. 8), the court issued an order (doc. no. 9) directing petitioner

either to forego his unexhausted claims, or to notify the court

that he wished to return to the state court to exhaust his

unexhausted claims, and, once they were exhausted, to file an

amended petition in this court to so demonstrate. The report and

recommendation was approved on November 26, 2007 (doc. no. 11).

At Ayer’s request, the court stayed this matter on June 19,

2008. Ayer then spent more than five years pursuing post-

conviction relief in the state courts. On October 23, 2013, upon

Ayer’s assertion that his state court proceedings were complete,

this court lifted the stay and directed Ayer to file a renewed

motion for relief. Ayer has now filed a motion entitled “Motion

for Summary Judgment” (doc. no. 50), a motion for court-appointed

counsel (doc. no. 51), and a “Renewed Motion for Relief” (doc.

no. 52).

Discussion

I. Preliminary Review

A. Construction of Pleadings

The court finds that Ayer’s motion for summary judgment

(doc. no. 50) and his renewed motion for relief (doc. no. 52) are

in fact requests to amend his original habeas petition (doc. no.

1) to add two ineffective assistance of trial counsel claims, and

to demonstrate exhaustion. The court thus construes both motions

2 as motions to amend the petition, and grants the motions. The

original petition (doc. no. 1), along with the assertions in the

motions to amend (doc. nos. 50 and 52), will be considered to be

the amended petition in this matter for all purposes. The court

thus proceeds to review the amended petition, pursuant to § 2254

Rule 4.

B. Standard

In undertaking § 2254 Rule 4 preliminary review, this court

decides whether the petition contains sufficient factual matter,

accepted as true, to state a claim to relief that is plausible on

its face and cognizable in a federal habeas action. See

McFarland v. Scott, 512 U.S. 849, 856 (1994) (“Federal courts are

authorized to dismiss summarily any habeas petition that appears

legally insufficient on its face.”). When a habeas petitioner is

proceeding pro se, the assertions contained in the petition are

construed liberally. See Erickson v. Pardus, 551 U.S. 89, 94

(2007) (per curiam).

C. Claims

In the 2007 report and recommendation (doc. no. 8), the

court identified the following cognizable claims for relief:

1. Ayer was denied his Fifth, Sixth, and Fourteenth Amendment rights to represent himself at trial when the trial court “forced” him to have court-appointed counsel;

3 2. Ayer was denied his Sixth and Fourteenth Amendment right to the effective assistance of counsel when his appointed trial counsel:

a. Refused to file an interlocutory appeal of the trial court’s denial of Ayer’s right to proceed pro se at trial;

b. Did not preserve, for the appellate record in the case, Ayer’s objection to being provided with court-appointed counsel;

c. Refused to obtain weapons and forensics experts who could have provided exculpatory information;

d. Refused to present defenses based on Ayer’s State constitutional right to bear arms in defense of himself, other people, or his property and his State constitutional right to revolution;

e. Refused to call as witnesses at petitioner’s trial individuals who had been involved in protests against the New Hampshire Department of Health and Human Services Division of Children, Youth, and Families (“DCYF”);

f. Refused to call as witnesses at petitioner’s trial employees of DCYF who were of the opinion that DCYF was not effectively performing its intended functions;

g. Refused to investigate child abuse allegations against DCYF from 1998 to use in Ayer’s defense at trial; and

h. At Ayer’s retrial, read a transcript of the testimony of a witness at the first trial who was deceased at the time of the second trial;

3. Ayer’s Sixth and Fourteenth Amendment right to confront the witnesses and evidence against him was violated when the trial court admitted testimony of a witness who had died between Ayer’s first and second trials, and whose testimony was recorded at the first trial;

4 4. Ayer’s Fifth, Sixth, and Fourteenth Amendment rights to Due Process and a fair trial were violated when the trial court denied Ayer the ability to present certain defenses to the jury for consideration;

5. Ayer’s Fifth, Sixth, and Fourteenth Amendment rights to Due Process and a fair trial were violated when the trial court refused to instruct the jury regarding the lesser offense of provocation manslaughter;

6. Ayer’s Fifth and Fourteenth Amendment rights to Due Process and not to incriminate himself were violated when his statements were admitted at trial even though he had not voluntarily waived the rights afforded to him by Miranda v. Arizona, 396 U.S. 868 (1969);

7. Ayer’s Fifth and Fourteenth Amendment rights to Due Process and not to incriminate himself were violated when his statements were admitted at trial even though he had invoked his right to counsel prior to questioning, but was not afforded counsel at that time;

8. [Dismissed by order (doc. no. 11)]

9. Ayer’s Fifth and Fourteenth Amendment Due Process rights were violated when the trial court admitted in evidence firearms, weapons, and ammunition that was found in Ayer’s truck even though the items were not used in the commission of the crime, were highly prejudicial, and were not introduced for a legitimate purpose; and

10. Ayer’s Sixth and Fourteenth Amendment right to confront the witnesses against him was violated when the trial court erroneously admitted certain testimonial statements made by Ayer’s wife, who did not testify, through another witness, as excited utterances.

In his amended petition, Ayer asserts the following two

additional claims of ineffective assistance of counsel, numbered

11 and 12 in this matter:

5 11.

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Related

Matter of Parrish
7 F.3d 76 (Fifth Circuit, 1993)
McFarland v. Scott
512 U.S. 849 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Word v. Lord
648 F.3d 129 (Second Circuit, 2011)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
DeLong v. Dickhaut
715 F.3d 382 (First Circuit, 2013)
Miranda v. Arizona
396 U.S. 868 (Supreme Court, 1969)

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2014 DNH 087, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ayer-v-nhsp-warden-nhd-2014.