Blann v. Lumpkin-Director TDCJ-CID

CourtDistrict Court, W.D. Texas
DecidedDecember 17, 2021
Docket6:20-cv-01072
StatusUnknown

This text of Blann v. Lumpkin-Director TDCJ-CID (Blann v. Lumpkin-Director TDCJ-CID) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blann v. Lumpkin-Director TDCJ-CID, (W.D. Tex. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION

JAMES BLANN, § TDCJ No. 02301954, § § Petitioner, § § v. § W-20-CV-1072-ADA § BOBBY LUMPKIN, Director, § Texas Department of Criminal Justice, § Correctional Institutions Division, § § Respondent. §

ORDER

Before the Court are Petitioner James Blann’s pro se Petition for Writ of Habeas Corpus pursuant to 28 U.S.C. § 2254 (ECF No. 1) and Respondent’s Response (ECF No. 8). Having reviewed the record and pleadings submitted by both parties, the Court concludes Petitioner’s federal habeas corpus petition should be denied under the standards prescribed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). 28 U.S.C. § 2254(d). I. Background In September 2019, Petitioner was charged by indictment with one count of deadly conduct: discharging a firearm into a habitation, building, or vehicle. (ECF No. 9-2 at 4- 6.) In November 2019, and pursuant to an open plea, Petitioner pled guilty to the charge; in January 2020, he was sentenced to eight years imprisonment. , No. 81028 (426th Dist. Ct., Bell Cnty., Tex. Jan. 6, 2020). ( at 17, 24-26.) Petitioner did 1 not file a direct appeal, a Petition for Discretionary Review with the Texas Court of Criminal Appeals (TCCA), or a Petition for Writ of Certiorari with the United States Supreme Court.

On May 27, 2020, Petitioner filed his state habeas corpus application, listing the following four grounds of relief: 1. Petitioner’s trial counsel provided ineffective assistance he allowed a different judge to preside over Petitioner’s sentencing than the judge who took Petitioner’s guilty plea;

2. The State destroyed evidence and failed to disclose proper evidence at Petitioner’s sentencing hearing. The deficiencies put Petitioner under duress and caused him to involuntarily plead guilty. Further, the State failed to disclose Petitioner’s mental illness.

3. Petitioner’s Due Process rights were violated when the State failed to notify Petitioner that a witness would testify at his sentencing hearing. His Due Process rights were also violated when he agreed to a five year sentence but was sentenced to eight years imprisonment.

4. Petitioner’s guilty plea and sentence violated and the Ex Post Facto Clause.

( at 64-81.) On August 25, 2020, the state habeas court adopted the State’s Findings of Fact and Conclusions of Law and recommended denying the application. ( at 113-23.) On October 14, 2020, the TCCA denied Petitioner’s application without written order on the findings of the trial court without hearing and on the court’s independent review of the record. (ECF No. 9-1.) On November 10, 2020, Petitioner filed his federal petition for a writ of habeas corpus, listing the following four grounds of relief: 2 1. Trial counsel provided ineffective assistance when Petitioner pleaded guilty in one court but was sentenced to eight years imprisonment in another court.

2. The State violated Petitioner’s right to equal protection by withholding information about his mental health.

3. The State violated Petitioner’s due process rights when it failed to notify him of a witness at the sentencing hearing and when it reneged on the five-year plea bargain.

4. Petitioner’s guilty plea and sentence violate the Constitution’s Ex Post Facto clause.

(ECF No. 1.) On January 21, 2021, Respondent filed their response. (ECF No. 13.) II. Standard of Review Petitioner’s federal habeas petition is governed by the heightened standard of review provided by AEDPA. 28 U.S.C. § 2254. Under § 2254(d), a petitioner may not obtain federal habeas corpus relief on any claim that was adjudicated on the merits in state court proceedings unless the adjudication of that claim either (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 (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. , 544 U.S. 133, 141 (2005). This demanding standard stops just short of imposing a complete bar on federal court re-litigation of claims already rejected in state proceedings. , 562 U.S. 86, 102 (2011) (citing , 518 U.S. 651, 664 (1996)). A federal habeas court’s inquiry into unreasonableness always should be objective rather than subjective, with a focus on whether the state court’s application of clearly established federal law was “objectively unreasonable” and not whether it was incorrect 3 or erroneous. , 539 U.S. 510, 520-21 (2003) (citing , 529 U.S. 362, 409 (2000)). Even a strong case for relief does not mean the state court’s contrary conclusion was unreasonable. , 562 U.S. at 102. A petitioner must show

that the state court’s decision was objectively unreasonable, which is a “substantially higher threshold.” , 550 U.S. 465, 473 (2007); , 538 U.S. 63, 75-76 (2003). “A state court’s determination that a claim lacks merit precludes federal habeas relief so long as ‘fairminded jurists could disagree’ on the correctness of the state court’s decision.” , 562 U.S. at 101 (citation omitted). As a result, to obtain federal habeas relief on a claim previously adjudicated on the merits

in state court, Petitioner must show that the state court’s ruling “was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement.” . at 103; , 565 U.S. 23, 24 (2011). “‘If this standard is difficult to meet—and it is—that is because it was meant to be.’” , 906 F.3d 307, 314 (5th Cir. 2018) (quoting , 571 U.S. 12, 20 (2013)). III. Analysis

1. Petitioner’s Guilty Plea Petitioner’s habeas petition attacks his guilty plea by arguing it is invalid based on ineffective assistance of counsel and violations of Due Process, Equal Protection, and the Ex Post Facto clause. It is axiomatic that a guilty plea is valid only if entered into voluntarily, knowingly, and intelligently, “with sufficient awareness of the relevant circumstances and likely consequences.” , 545 U.S. 175, 183 (2005); 4 , 234 F.3d 252, 254 (5th Cir. 2000). A plea is intelligently made when the defendant has “‘real notice of the true nature of the charge against him.’” , 523 U.S. 614, 618 (1998) (citing , 312 U.S.

329, 334 (1941)). A plea is voluntary if it does not result from force, threats, improper promises, misrepresentations, or coercion. , 111 F.3d 386, 389 (5th Cir. 1997). “The longstanding test for determining the validity of a guilty plea is ‘whether the plea represents a voluntary and intelligent choice among the alternative courses of action open to the defendant.’” , 474 U.S. 52, 56 (1985) (quoting , 400 U.S. 25, 31 (1970)); , 672

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