Banks v. King

CourtDistrict Court, E.D. Michigan
DecidedSeptember 23, 2025
Docket4:23-cv-10947
StatusUnknown

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

Bluebook
Banks v. King, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

ANTONIO BANKS,

Petitioner, CASE NO. 4:23-CV-10947 v. HONORABLE F. KAY BEHM

CHRIS KING,

Respondent.

______ /

OPINION & ORDER DENYING THE HABEAS PETITION, DENYING A CERTIFICATE OF APPEALABILITY, AND DENYING LEAVE TO PROCEED IN FORMA PAUPERIS ON APPEAL

I. Introduction Michigan prisoner Antonio Banks (“Petitioner”), through counsel, has filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. ' 2254 challenging his state court convictions. Petitioner pleaded guilty to two counts of second-degree murder, Mich. Comp. Laws § 750.317, two counts of operating a motor vehicle while under the influence causing serious injury, Mich. Comp. Laws § 257.625(5), and being a second habitual offender, Mich. Comp. Laws § 769.10, in the Wayne County Circuit Court. He was sentenced to concurrent terms of 18 years 9 months to 30 years in prison on the murder convictions and 3 years to 7 years 6 months in prison on the operating under the influence convictions in 2017. In his pleadings, he raises claims concerning his right to counsel of choice, the effectiveness of trial counsel, and the voluntariness of his plea. For the reasons set forth, the Court

denies the habeas petition, denies a certificate of appealability, and denies leave to proceed in forma pauperis on appeal. II. Facts and Procedural History

Petitioner’s convictions arise from a high speed, drunk driving accident on May 14, 2017 in Detroit, Michigan in which he killed two people and injured several others. He was charged with eight counts: two counts of second-degree murder, Mich. Comp. Laws § 750.317, two counts of operating a motor vehicle

while under the influence causing death, Mich. Comp. Laws § 257.625(4), two counts of operating a motor vehicle while under the influence causing serious injury, Mich. Comp. Laws § 257.625(5), and two counts of reckless driving

causing serious impairment of a body function, Mich. Comp. Laws § 257.626(3). During the pre-trial period, Petitioner’s trial counsel filed motions to quash, to challenge the Petitioner’s hospital statement to police, and to withdraw due to a breakdown in the attorney-client relationship. While those motions were pending,

the parties entered into a written plea and sentencing agreement and appeared before the trial court for plea hearing with a Cobbs evaluation. At that hearing, Petitioner confirmed on the record that he wished to withdraw all three motions

and proceed with a plea. See 8/25/17 Plea Hrg. Tr., ECF No. 9-4, PageID.210-214. 2 Petitioner proceeded to plead guilty to two counts of second-degree murder, two counts of operating a motor vehicle while under the influence causing serious

injury, and being a second habitual offender in exchange for dismissal of the other charges and a Cobbs agreement that he would be sentenced to 18 years 9 months to 30 years in prison (a sentence within the guidelines). Id. at PageID.204-206, 209,

212, 218. The trial court subsequently sentenced him in accordance with the plea and sentencing agreement to concurrent terms of 18 years 9 months to 30 years in prison on the murder convictions and 3 years to 7 years 6 months on the operating

while intoxicated convictions. See 10/10/17 Sent. Tr., ECF No. 9-6, PageID.238- 239. Following sentencing, Petitioner filed a delayed application for leave to

appeal with the Michigan Court of Appeals raising claims concerning his right to counsel of choice and the effectiveness of trial counsel. The court denied the application for “for lack of merit in the grounds presented.” People v. Banks, No. 341954 (Mich. Ct. App. Feb. 22, 2018); ECF No. 9-8, PageID.249. Petitioner filed

an application for leave to appeal with the Michigan Supreme Court, which was denied in a standard order. People v. Banks, 503 Mich. 860, 917 N.W.2d 371 (2018).

3 Petitioner subsequently filed a motion for relief from judgment with the state trial court raising claims concerning the effectiveness of trial and appellate counsel

and the voluntariness of his plea. The court denied the motion, essentially finding that the claims lacked merit. People v. Banks, No. 17-004910-01-FC (Wayne Co. Cir. Ct. July 1, 2019); ECF No. 9-7, PageID.244-248. More than two years later,

the trial court entered a stipulated order re-denying the motion for relief from judgment to allow for a timely appeal due to the lack of notice of its prior decision. People v. Banks, No. 17-004910-01-FC (Wayne Co. Cir. Ct. Sept. 15, 2021); ECF No. 6-5, PageID.82-83. Petitioner then filed a delayed application for leave to

appeal in the Michigan Court of Appeals, which was denied for failure to establish that the trial court erred in denying the motion for relief from judgment. People v. Banks, No. 359670 (Mich. Ct. App. April 1, 2022); ECF No. 9-10, PageID.354.

Petitioner filed an application for leave to appeal with the Michigan Supreme Court, which was denied pursuant to Michigan Court Rule 6.508(D). People v. Banks, 510 Mich. 865, 977 N.W.2d 553 (2022). Petitioner also filed a motion for reconsideration, which was denied in a standard order. People v. Banks, 510 Mich.

951, 979 N.W.2d 831 (2022). Petitioner, through counsel, thereafter filed his federal habeas petition with a supporting brief raising the following claims:

4 I. He was deprived of his right to counsel of choice during plea proceedings when the trial court refused a request to terminate his retained attorney because of a breakdown in the attorney- client relationship.

II. He was denied effective assistance of counsel during the plea process because his attorney failed or refused to consider a nolo plea to avoid civil liability and withdrew a dispositive motion to suppress his statement.

III. His guilty plea was involuntary because he was not advised of the maximum possible sentence before pleading.

ECF Nos. 1, 6. Respondent filed an answer to the petition contending that it should be denied because the third claim is procedurally defaulted and all of the claims lack merit. ECF No. 10. Petitioner filed a reply to that answer. ECF No. 11. III. Standard of Review The Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), codified at 28 U.S.C. § 2241 et seq., sets forth the standard of review that federal courts must use when considering habeas petitions brought by prisoners challenging their state court convictions and sentences. The AEDPA provides in relevant part: An application for a writ of habeas corpus on behalf of a person in custody pursuant to the judgment of a State court shall not be granted with respect to any claim that was adjudicated on the merits in State court proceedings unless the 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 5 (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. § 2254(d) (1996). “A state court’s decision is ‘contrary to’ ... clearly established law if it ‘applies a rule that contradicts the governing law set forth in [Supreme Court cases]’ or if it >confronts a set of facts that are materially indistinguishable from a decision of [the Supreme] Court and nevertheless arrives at a result different from [that] precedent.’” Mitchell v. Esparza, 540 U.S. 12

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Bluebook (online)
Banks v. King, Counsel Stack Legal Research, https://law.counselstack.com/opinion/banks-v-king-mied-2025.