Bramlett v. Crow

CourtCourt of Appeals for the Tenth Circuit
DecidedMarch 13, 2023
Docket22-5079
StatusUnpublished

This text of Bramlett v. Crow (Bramlett v. Crow) 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
Bramlett v. Crow, (10th Cir. 2023).

Opinion

Appellate Case: 22-5079 Document: 010110825530 Date Filed: 03/13/2023 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT March 13, 2023 _______________________________________ Christopher M. Wolpert Clerk of Court RENESE BRAMLETT,

Petitioner - Appellant,

v. No. 22-5079 (D.C. No. 4:20-CV-00537-JFH-CDL) SCOTT CROW, (N.D. Okla.)

Respondent - Appellee. _______________________________________

ORDER _______________________________________

Before BACHARACH, BALDOCK, and McHUGH, Circuit Judges. _______________________________________

Mr. Renese Bramlett was convicted of first-degree murder. The

prosecution didn’t seek the death penalty, so a life sentence was

mandatory; but the jury could include the possibility of parole or deny that

possibility. The jury opted to deny the possibility of parole.

Mr. Bramlett unsuccessfully pursued state-court remedies (including

a direct appeal and post-conviction appeal) and petitioned in federal

district court for a writ of habeas corpus. In his federal habeas petition, he

claimed in part that Oklahoma’s statutory procedure had violated his right Appellate Case: 22-5079 Document: 010110825530 Date Filed: 03/13/2023 Page: 2

to due process. 1 The district court rejected the habeas claim, and Mr.

Bramlett wants to appeal.

He not only renews his habeas claim for denial of due process, but

also asserts a new claim: ineffective assistance of counsel for failing to

object to the prosecutor’s closing argument.

I. The state-law claim doesn’t provide an arguable basis for habeas relief.

Because Mr. Bramlett seeks to attack the “process issued by a State

court,” he can appeal only upon the issuance of a certificate of

appealability. 28 U.S.C. § 2253(c)(1)(A). We can issue a certificate only if

Mr. Bramlett made a “substantial showing of the denial of a constitutional

right.” 28 U.S.C. § 2253(c)(2). To assess the strength of that showing, we

consider whether reasonable jurists could “find the district court’s

assessment of the constitutional claims debatable or wrong.” Slack v.

McDaniel, 529 U.S. 473, 484 (2000).

Mr. Bramlett invokes the Fourteenth Amendment’s due process

clause based on the State’s opportunity to present evidence in aggravation

1 Mr. Bramlett also claimed misconduct by the prosecutor for appealing to sympathy. The state appellate court rejected this claim under the plain-error standard, and the federal district court held that the state appellate court’s decision was not contrary to clearly established federal law or an unreasonable application of a clearly established right. Here Mr. Bramlett doesn’t renew his claim for prosecutorial misconduct. But he does allege ineffective assistance of his trial attorney for failing to object to the prosecutor’s remarks. 2 Appellate Case: 22-5079 Document: 010110825530 Date Filed: 03/13/2023 Page: 3

and the defendant’s inability to present evidence in mitigation. Okla. Stat.

tit. 21 § 701.10-1(A). We must consider the debatability of this claim

based on the underlying statutory restrictions for habeas relief. See Miller-

El v. Cockrell, 537 U.S. 322, 336 (2003) (stating that when deciding

whether to grant a certificate of appealability, the Court “look[s] to the

District Court’s application of [The Antiterrorism and Effective Death

Penalty Act] to petitioner’s constitutional claims.”). These statutory

restrictions would prevent habeas relief in the absence of (1) a clearly

established constitutional right as determined by the Supreme Court or (2)

an unreasonable determination of facts. 28 U.S.C. § 2254(d).

The federal district court rejected Mr. Bramlett’s claim, reasoning

that the Supreme Court has never recognized a constitutional right to

present mitigating evidence in non-capital cases. We agree with this

reasoning to the extent that it bears on part of Mr. Bramlett’s habeas claim.

The Supreme Court has rejected Eighth Amendment claims involving the

inability to present mitigating evidence in noncapital cases. See Harmelin

v. Michigan, 501 U.S. 957, 994–95 (1991) (regarding an Eighth

Amendment challenge to a sentence of life imprisonment based on the

failure to consider mitigating factors); Gilmore v. Taylor, 508 U.S. 333,

349 (1993) (O’Connor, J., concurring) (“We have not held that the Eighth

Amendment’s requirement that the jury be allowed to consider and give

effect to all relevant mitigating evidence in capital cases . . . applies to

3 Appellate Case: 22-5079 Document: 010110825530 Date Filed: 03/13/2023 Page: 4

noncapital cases.”). To date, the Supreme Court has not addressed whether

due process entitles noncapital defendants to present mitigating evidence.

So no jurist could reasonably find a Supreme Court precedent that clearly

establishes a right under the Due Process Clause to present mitigating

evidence in noncapital cases. 2

But Mr. Bramlett’s claim goes beyond his inability to present

mitigating evidence. He claims that Oklahoma law unfairly allows the State

to present aggravating evidence while disallowing a comparable right for

defendants to present mitigating evidence.

The state statute exists as part of Oklahoma’s procedure for

bifurcating criminal cases when the prosecutor seeks enhancement of a

sentence based on prior felony convictions. Mahdavi v. State, 478 P.3d

449, 462 (Okla. Crim. App. 2020) (Kuehn, V.P.J., concurring in the result).

The state procedure authorizes bifurcation of criminal cases when the

prosecution has a right to present evidence of prior felony convictions.

Okla. Stat. tit. 21 § 701.10-1(a). Through bifurcation, the procedure is

designed to prevent prosecutors from using prior felony convictions during

the guilt phase of a criminal trial.

2 We’ve held that the right to due process does not entitle defendants in noncapital cases to present mitigating evidence. Scrivner v. Tansy, 68 F.3d 1234, 1240 (10th Cir. 1995).

4 Appellate Case: 22-5079 Document: 010110825530 Date Filed: 03/13/2023 Page: 5

To determine whether this procedure triggers a denial of due process,

we consider whether the procedure “offends some principle of justice so

rooted in the traditions and conscience of our people as to be ranked as

fundamental.” Medina v. California, 505 U.S. 437, 445 (1992) (quoting

Patterson v. New York, 432 U.S. 197, 202 (1977)). We thus apply this

standard to the state’s procedure for bifurcation when prior felony

convictions are inadmissible at the guilt stage and admissible for

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Related

Patterson v. New York
432 U.S. 197 (Supreme Court, 1977)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Harmelin v. Michigan
501 U.S. 957 (Supreme Court, 1991)
Medina v. California
505 U.S. 437 (Supreme Court, 1992)
Gilmore v. Taylor
508 U.S. 333 (Supreme Court, 1993)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Cummings v. Sirmons
506 F.3d 1211 (Tenth Circuit, 2007)
MAHDAVI v. STATE
2020 OK CR 12 (Court of Criminal Appeals of Oklahoma, 2020)
Scrivner v. Tansy
68 F.3d 1234 (Tenth Circuit, 1995)

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