Bias v. Warden, Lebanon Correctional Institution

District Court, S.D. Ohio·Decided May 14, 2024·No. 2:23-cv-02313·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

DEVON BIAS,

Petitioner, : Case No. 2:23-cv-02313 - vs - Judge Sarah D. Morrison Magistrate Judge Michael R. Merz WARDEN, Lebanon Correctional Institution, : Respondent. DECISION AND ORDER

This habeas corpus case is before the Court on Petitioner’s Objections (ECF Nos. 29 and 32) to, respectively, the Magistrate Judge’s Report and Recommendations recommending dismissal of the Petition (ECF No. 26) and to the Magistrate Judge’s Supplemental Report and Recommendations reaching the same conclusion (ECF No. 31). Respondent has replied to Petitioner’s Objections to the Supplemental Report (ECF No. 33). As required by 28 U.S.C. § 636(b)(1) and Fed.R.Civ.P. 72(b), the Court has reviewed de novo the Reports with particular attention to those portions objected to by Petitioner. Having done so, the Court finds the objections are without merit and they are OVERRULED for the reasons set forth below: Ground One: Violation of the Confrontation Clause

In his First Ground for Relief, Petitioner claims that his rights under the Confrontation Clause “and/or Fed. R. Evid. 804” were violated when the prosecutor failed to make a sufficient good faith effort to obtain the live testimony of witness Jaw.L. The original Report noted that Fed. R. Evid. 804 does not apply to state trials and this Court could not review the Ohio Tenth District’s application of the parallel

Ohio R. Evid. 804 because that is purely a question of state law. Petitioner objects to this latter finding, claiming that 28 U.S.C. § 2254(e)(2) allows federal courts to intervene on questions of state law “if the state courts factual determinations were incorrect or resulted in a decision that was based on an unreasonable determination of the facts.” (ECF No. 32, PageID 1978). Not so. § 2254(e)(2) deals with when a federal habeas court may hold an evidentiary hearing. The more relevant provision of the Antiterrorism and Effective Death Penalty Act of

1996 (Pub. L. No 104-132, 110 Stat. 1214)(the "AEDPA") is § 2254(d)(2) which permits granting the writ of habeas corpus when the state courts have decided the merits of a habeas claim but their decision “is based on an unreasonable determination of the facts.” No provision of the AEDPA authorizes a habeas court to review the application of a rule of state evidence law by a state court. Petitioner’s second objection as to Ground One is that the Magistrate Judge

concluded the Ohio courts’ finding that Petitioner caused Jaw.L’s unavailability was a reasonable conclusion on the basis of the facts presented. The original Report repeats at length the Tenth District’s basis for that finding (ECF No. 26, PageID 1915, et seq.). Having reviewed that finding in context, the Court finds the conclusion that Petitioner caused Jaw.L’s unavailability and thus satisfied the Confrontation Clause exception recognized in Giles v. California, 554 U.S. 353 (2008), is a completely reasonable conclusion from the evidence offered. Ground Two: Violation of the Confrontation Clause In his Second Ground for Relief Petitioner again complains of the state court

determination that he caused Jaw.L’s unavailability, this time based on the fact that the trial judge found Bias was the author of the kidnap1 letter by comparing the handwriting in that letter with a sample of Petitioner’s handwriting in the form of a pro se motion. The Magistrate Judge recommended dismissal of the Second Ground on the merits. Petitioner objects that the trial judge was prohibited from making that finding by “Supreme Court precedent in Crater v. Galaza, 491 F.3d 1119 (9th Cir. 2007).”

(ECF No. 32, PageID 1979-80). Crater is, of course, not Supreme Court precedent, but it is also inapposite. The Ninth Circuit in that case declined to find a judge biased who had urged a defendant at a pretrial conference to accept a plea bargain. Judge Holbrook in this case did not act as part of the accusatory process. Rather he appropriately acted as part of the adjudicatory process by finding Petitioner’s handwriting in a pro se motion matched the handwriting in the kidnap

latter. A judge does not become a biased participant when he reaches a conclusion adverse to a party’s position. Ground Three: Violation of the Confrontation Clause Petitioner makes no substantive objections to the recommended dismissal of

1A letter instructing a female friend of Petitioner’s how to arrange Jaw.L’s kidnapping. this Ground for Relief. Ground Four: Due Process Violation: Suggestive Pretrial Identification Procedure

In his Fourth Ground for Relief, Petitioner asserts that Jaw.L’s pretrial identification from a photo array was unduly suggestive. The state courts found as a matter of fact that this was not so, noting the police had used a blind administrator for the photo array as required by Ohio law and finding the administrator did not suggest picking Petitioner’s photograph. The Magistrate Judge found these factual conclusions were entitled to deference. Petitioner disagrees with the state court findings, but points to no evidence which would deprive those findings of their presumption of correctness. For example, he fastens on the administrator’s having told the witness that he knew “very little” about the case, but posits that “very little” could include knowing who the suspect was. A habeas petitioner cannot defeat

required deference to state court findings by hypothesizing facts not in evidence. There is no evidence the administrator was not blind to the suspect’s identity, as the Ohio courts found. Ground Five: Judicial Bias In his Fifth Ground for Relief, Petitioner asserts he is entitled to relief because the trial judge was disqualified by bias from trying the case after he sat as the finder of fact in the certification hearing2. The Magistrate Judge found this claim was

procedurally defaulted by failure to present it on direct appeal. Petitioner claims

2A pretrial hearing to determine whether a defendant has caused the unavailability of a witness. relief from the default by actual innocence as recognized in McQuiggin v. Perkins, 569 U.S. 383 (2013). The Magistrate Judge rejected Petitioner’s actual innocence claim on the

ground that his evidence of alibi did not satisfy the standards of McQuiggin. In his Objections, Petitioner argues the strength of that evidence, but the Court agrees with the Magistrate Judge that it is very weak and not sufficient to establish actual innocence to the standard required by Schlup v. Delo, 513 U.S. 298 (1995). Petitioner reiterates his claim that Judge Holbrook’s failure to recuse himself violated the Ohio Code of Judicial Conduct. Whether or not that is the case, violations of that Code are not cognizable in a habeas corpus case; we are authorized

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