Battle v. Williams

CourtDistrict Court, D. Nevada
DecidedMay 21, 2020
Docket2:19-cv-00453
StatusUnknown

This text of Battle v. Williams (Battle v. Williams) 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
Battle v. Williams, (D. Nev. 2020).

Opinion

5 UNITED STATES DISTRICT COURT 6 DISTRICT OF NEVADA 7 * * * 8 EVINE BATTLE, Case No. 2:19-cv-00453-GMN-DJA 9 Petitioner, 10 v. ORDER

11 BRIAN WILLIAMS, et al., 12 Respondents. 13 14 15 Before the court for a decision on the merits is a petition for a writ of habeas 16 corpus filed by Evine Battle. ECF No. 7. For reasons that follow, the petition will be 17 denied. 18 I. BACKGROUND1 19 In May 2015, a jury sitting in the Eighth Judicial District Court for Clark County, 20 Nevada, found Battle guilty of burglary while in possession of a deadly weapon, first 21 degree kidnapping with use of a deadly weapon, robbery with use of a deadly weapon, 22 and carrying concealed firearm or other deadly weapon.2 The Nevada Supreme Court 23 recounted the facts of his case as follows:

24 A GameStop store was robbed and an employee, Michelle Tyler, was restrained in the store's bathroom. Immediately after the incident, 25 Tyler told police she would be unable to identify the culprit. Three days 26 1 This background is derived from exhibits filed at ECF Nos. 13-17 and from this court’s own docket. 27 2 The jury acquitted Battle on two counts related to an alleged robbery of a 7-Eleven. later, appellant Evine Battle was apprehended at a Jack in the Box 1 restaurant after acting suspiciously. Battle was dressed similarly to the individual in the GameStop incident, and police found a concealed firearm 2 in his sweatshirt. Four days after the GameStop incident, Tyler was shown a photo lineup and identified Battle as the culprit, although Tyler noted that 3 she was not 100 percent sure about the identification. 4 ECF No. 16-6 at 2. 5 The state district court sentenced Battle to an aggregate term of 360 months in prison 6 with the possibility of parole after 120 months. A judgment of conviction was entered in 7 August 2015. 8 Battle appealed his judgment of conviction arguing that insufficient evidence was 9 presented at trial to convict him on the three charges related to the GameStop incident 10 and that his venire was not composed of a fair cross-section of Clark County because 11 African Americans were underrepresented. The Nevada Supreme Court rejected those 12 arguments and affirmed Battle’s convictions. 13 In August 2017, Battle filed a pro se petition for writ of habeas corpus with the 14 state district court. In his state petition, he raised claims of ineffective assistance of trial 15 counsel and appellate counsel. The state district court denied relief. On appeal, Battle 16 raised additional claims of ineffective assistance of counsel. The Nevada Court of 17 Appeals affirmed the state district court’s order denying habeas relief in January 2019. 18 Battle initiated this proceeding on March 12, 2019. Respondents filed an answer 19 to the petition, in response to which Battle filed a reply. The court now addresses 20 petitioner’s four grounds for relief on the merits. 21 II. STANDARDS OF REVIEW 22 This action is governed by the Antiterrorism and Effective Death Penalty Act 23 (AEDPA). 28 U.S.C. § 2254(d) sets forth the standard of review under AEDPA:

24 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 25 respect to any claim that was adjudicated on the merits in State court proceedings unless the adjudication of the claim – 26 27 (1) resulted in a decision that was contrary to, or involved an 1 unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or 2 (2) resulted in a decision that was based on an unreasonable 3 determination of the facts in light of the evidence presented in the State court proceeding. 4 5 A decision of a state court is "contrary to" clearly established federal law if the 6 state court arrives at a conclusion opposite that reached by the Supreme Court on a 7 question of law or if the state court decides a case differently than the Supreme Court 8 has on a set of materially indistinguishable facts. Williams v. Taylor, 529 U.S. 362, 405- 9 06 (2000). An "unreasonable application" occurs when "a state-court decision 10 unreasonably applies the law of [the Supreme Court] to the facts of a prisoner's case." 11 Id. at 409. "[A] federal habeas court may not "issue the writ simply because that court 12 concludes in its independent judgment that the relevant state-court decision applied 13 clearly established federal law erroneously or incorrectly." Id. at 411. 14 The Supreme Court has explained that "[a] federal court's collateral review of a 15 state-court decision must be consistent with the respect due state courts in our federal 16 system." Miller-El v. Cockrell, 537 U.S. 322, 340 (2003). The "AEDPA thus imposes a 17 'highly deferential standard for evaluating state-court rulings,' and 'demands that state- 18 court decisions be given the benefit of the doubt.'" Renico v. Lett, 559 U.S. 766, 773 19 (2010) (quoting Lindh v. Murphy, 521 U.S. 320, 333, n. 7 (1997); Woodford v. Viscotti, 20 537 U.S. 19, 24 (2002) (per curiam)). "A state court's determination that a claim lacks 21 merit precludes federal habeas relief so long as 'fairminded jurists could disagree' on 22 the correctness of the state court's decision." Harrington v. Richter, 562 U.S. 86, 101 23 (2011) (citing Yarborough v. Alvarado, 541 U.S. 652, 664 (2004)). The Supreme Court 24 has emphasized "that even a strong case for relief does not mean the state court's 25 contrary conclusion was unreasonable." Id. (citing Lockyer v. Andrade, 538 U.S. 63, 75 26 (2003)); see also Cullen v. Pinholster, 563 U.S. 170, 181 (2011) (describing the AEDPA 27 standard as "a difficult to meet and highly deferential standard for evaluating state-court 1 rulings, which demands that state-court decisions be given the benefit of the doubt") 2 (internal quotation marks and citations omitted). 3 "[A] federal court may not second-guess a state court's fact-finding process 4 unless, after review of the state-court record, it determines that the state court was not 5 merely wrong, but actually unreasonable." Taylor v. Maddox, 366 F.3d 992, 999 (9th Cir. 6 2004), overruled on other grounds by Murray v. Schriro, 745 F.3d 984, 999–1000 (9th 7 Cir. 2014).; see also Miller-El, 537 U.S. at 340 ("[A] decision adjudicated on the merits in 8 a state court and based on a factual determination will not be overturned on factual 9 grounds unless objectively unreasonable in light of the evidence presented in the state- 10 court proceeding, § 2254(d)(2)."). 11 Because de novo review is more favorable to the petitioner, federal courts can 12 deny writs of habeas corpus under § 2254 by engaging in de novo review rather than 13 applying the deferential AEDPA standard. Berghuis v. Thompkins, 560 U.S. 370, 390 14 (2010). 15 III. DISCUSSION 16 Ground One – In Ground One, Battle alleges that his convictions in relation to the 17 GameStop incident are in violation of his constitutional rights because insufficient 18 evidence was presented at trial to convict him beyond reasonable doubt. In support of 19 this claim, he contends that the only evidence supporting the convictions is the 20 testimony of Michelle Tyler, which was unreliable.

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Battle v. Williams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/battle-v-williams-nvd-2020.