Bradford v. Quick

CourtCourt of Appeals for the Tenth Circuit
DecidedJune 11, 2024
Docket23-5075
StatusUnpublished

This text of Bradford v. Quick (Bradford v. Quick) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bradford v. Quick, (10th Cir. 2024).

Opinion

Appellate Case: 23-5075 Document: 010111063282 Date Filed: 06/11/2024 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT June 11, 2024 _________________________________ Christopher M. Wolpert Clerk of Court ERIC TYRONE BRADFORD,

Petitioner - Appellant,

v. No. 23-5075 (D.C. No. 4:22-CV-00458-JFH-SH) CHRISTE QUICK, (N.D. Okla.)

Respondent - Appellee. _________________________________

ORDER AND JUDGMENT* _________________________________

Before BACHARACH, BALDOCK, and MORITZ, Circuit Judges. _________________________________

Eric Tyrone Bradford, an Oklahoma prisoner proceeding pro se,1 filed an

application in district court for a writ of habeas corpus under 28 U.S.C. § 2254. The

district court dismissed the application because he had not exhausted his state court

remedies, but it granted a certificate of appealability (COA) on one issue. Exercising

* After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. 1 Because Mr. Bradford represents himself, we liberally construe his combined application for a COA and opening brief. See Hall v. Scott, 292 F.3d 1264, 1266 (10th Cir. 2002). Appellate Case: 23-5075 Document: 010111063282 Date Filed: 06/11/2024 Page: 2

jurisdiction under 28 U.S.C. §§ 1291 and 2253, we affirm on that issue and deny a COA

on the remaining issues.

I. BACKGROUND

A. State Proceedings

Mr. Bradford was convicted of first degree murder and two firearm offenses in

Oklahoma state court. On direct appeal, he raised two evidentiary challenges. The

Oklahoma Court of Criminal Appeals (OCCA) rejected both and affirmed. Mr. Bradford

did not seek further review.

Through counsel, Mr. Bradford filed an application for postconviction relief in

state district court claiming that court lacked subject matter jurisdiction over his case

under McGirt v. Oklahoma, 140 S. Ct. 2452 (2020), because the crime occurred in Indian

country and the victim was a member of the Muscogee (Creek) Nation.2 See id. at

2459-60 (holding that the territory in Oklahoma reserved for the Creek Nation since the

19th century remains “‘Indian country’” for purposes of exclusive federal jurisdiction

over “certain enumerated offenses” committed “within ‘the Indian country’” by an

“‘Indian.’” (quoting 18 U.S.C. § 1153(a))).

In April 2021, the state district court granted the application for postconviction

relief. But it stayed its order in light of a recent OCCA decision in another case involving

2 Mr. Bradford initially filed a pro se postconviction application in which he also alleged his mother and grandparents were members of the Creek Nation. He made no claim that his family were members of the Creek Nation in the amended application filed through counsel.

2 Appellate Case: 23-5075 Document: 010111063282 Date Filed: 06/11/2024 Page: 3

a McGirt issue.3 Soon thereafter, Mr. Bradford was charged in a federal case with crimes

stemming from the same conduct that gave rise to his state-court convictions. Then, in

August 2021, the state district court lifted the stay and denied postconviction relief in

light of State ex rel. Matloff v. Wallace, 497 P.3d 686, 689 (Okla. Crim. App. 2021), in

which the OCCA held that McGirt does not apply retroactively to convictions that were

final when McGirt was decided. Mr. Bradford’s federal prosecution was later dismissed.

Through counsel, Mr. Bradford appealed the denial of postconviction relief,

claiming (1) Matloff was wrongly decided and the district court erred in concluding that

McGirt does not apply retroactively; and (2) the district court abused its discretion in

denying postconviction relief because under McGirt, the state court “did not, nor has it

ever, had subject matter jurisdiction.” R., vol. 1 at 147, 157. The OCCA affirmed.

B. Federal Habeas Proceedings

After the state-court postconviction proceedings concluded, Mr. Bradford filed his

pro se § 2254 application. He raised claims alleging ineffective assistance of trial and

direct appeal counsel, prosecutorial misconduct, and “abuse of discretion” by the state

district court. R., vol. 2 at 11. For the third claim, he alleged (1) the judge violated a

state law and “overstep[ed] her jurisdictional boundaries” by referring him for federal

prosecution, id., vol. 1 at 18; (2) the court “lost jurisdiction and was unable to make any

3 In the other case the OCCA had initially granted postconviction relief and invalidated on Indian-country jurisdiction grounds convictions that were final before McGirt was decided, but later recalled its mandate to give the case further consideration. See Bosse v. State, 499 P.3d 771, 774-75 (Okla. Crim. App. 2021) (describing procedural history and denying relief on Indian-country jurisdictional claim because McGirt does not apply retroactively). 3 Appellate Case: 23-5075 Document: 010111063282 Date Filed: 06/11/2024 Page: 4

subsequent ruling” after the federal case was filed, id., vol. 2 at 24; (3) the court violated

his Fourth Amendment rights by continuing to exercise jurisdiction after “federal

authorities participated in kidnapping” him and detained him on the federal charges, id.;

and (4) the April 2021 order was “the correctly applied mandate and any subsequent

ruling was res judicata.” id., vol. 1 at 17.

The district court granted Respondent’s motion to dismiss Mr. Bradford’s § 2254

claims as unexhausted, noting his acknowledgment that he had not raised any of his

§ 2254 claims in state court, see id., vol. 2 at 8-9, 10, 12.4 The district court initially

denied a COA on all issues, but after Mr. Bradford filed a notice of appeal and motion for

COA, the court granted a COA on the following issue:

whether the Petition was erroneously dismissed as to claim three because [Mr.] Bradford raised a properly exhausted claim that the state district court violated his Fourteenth Amendment right to due process by reinstating his criminal judgment and sentence after issuing a final judgment in April 2021 granting his application for postconviction relief.

Id., vol. 1 at 290-91.

II. DISCUSSION

A. Appeal Issue

We review de novo the dismissal of a habeas application for failure to exhaust

state remedies. Allen v. Zavaras, 568 F.3d 1197

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Bradford v. Quick, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bradford-v-quick-ca10-2024.