Bryant v. Toney

CourtDistrict Court, S.D. Alabama
DecidedAugust 11, 2021
Docket1:18-cv-00363
StatusUnknown

This text of Bryant v. Toney (Bryant v. Toney) is published on Counsel Stack Legal Research, covering District Court, S.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bryant v. Toney, (S.D. Ala. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

FRED LEE BRYANT, ) AIS #00226616, ) Petitioner, ) ) v. ) CIVIL ACTION NO. 18-00363-TFM-N ) DEBORAH TONEY, Warden, ) Limestone Correctional Facility, ) et al. ) Respondents. ) REPORT AND RECOMMENDATIONS Petitioner Fred Lee Bryant, an Alabama prisoner proceeding with counsel, filed a Petition for a Writ of Habeas Corpus under 28 U.S.C. § 2254 (Doc. 5, PageID.3– 17).1 The District Judge presiding over this case referred Bryant’s petition to the undersigned Magistrate Judge who, under S.D. Ala. GenLR 72(a)(2)(R), is authorized to require responses, issue orders to show cause and any other orders necessary to develop a complete record, and to prepare a report and recommendation to the District Judge as to appropriate disposition of the petition, in accordance with 28 U.S.C. § 636(b)(1) and Rules 8(b) and 10 of the Rules Governing Section 2254 Cases in the United States District Courts. See S.D. Ala. GenLR 72(b); (11/30/2018 electronic referral).

1 In Bryant’s petition filed on the Court’s form (Doc. 5, PageID.3–17), he notes that his claims are explained in detail in an accompanying memorandum (Doc. 5, PageID.18–46). Upon transfer from the Northern District of Alabama to the Southern District of Alabama, Bryant filed an amended memorandum in support of the petition (Doc. 7) as a matter of course under Federal Rule of Civil Procedure 15(a)(1)(B), which the undersigned treats as the operative filing setting out Bryant’s claims. The Respondent, through the Office of the Attorney General of the State of Alabama, timely filed an Answer (Doc. 12) to the petition, to which Bryant filed a reply (Doc. 13). Bryant’s § 2254 petition is now under submission and is ripe for

disposition. Following a thorough review of the petition and record, the undersigned finds that an evidentiary hearing is not warranted.2 Upon consideration, the undersigned RECOMMENDS that Bryant’s habeas petition (Doc. 5, PageID.3–17) be DISMISSED with prejudice. The undersigned also RECOMMENDS that Bryant should be DENIED a Certificate of Appealability and leave to proceed in forma pauperis on appeal. I. Background

After a jury trial in Mobile County Circuit Court, Bryant was found guilty of murder in violation of Ala. Code § 13A-6-2. (Doc. 12-1, PageID.184). On February 5, 2015, the trial court sentenced Bryant to life imprisonment. (Doc. 12-1, PageID.182). Through counsel, Bryant appealed the conviction and sentence to the Alabama Court of Criminal Appeals, arguing that there was insufficient evidence to support the jury’s verdict. (Doc. 12-4, PageID.1267). The Alabama Court of Criminal Appeals affirmed

the guilty verdict in an unpublished memorandum opinion, finding that the State

2 This case is governed by the Antiterrorism and Effective Death Penalty Act (AEDPA) because Bryant filed his federal habeas petition after April 24, 1996. “AEDPA expressly limits the extent to which hearings are permissible, not merely the extent to which they are required.” Kelley v. Sec’y for the Dep’t of Corr., 377 F.3d 1317, 1337 (11th Cir. 2004). Bryant failed to establish that an evidentiary hearing is warranted in this case. Birt v. Montgomery, 725 F.2d 587, 591 (11th Cir. 1984) (en banc) (“The burden is on the petitioner . . . to establish the need for an evidentiary hearing.”). presented sufficient legal evidence from which a rational finder of fact could have, by fair inference, found Bryant guilty beyond a reasonable doubt. (Doc. 12-6, PageID.746). The Alabama Court of Criminal Appeals denied Bryant’s subsequent

request for a rehearing. (Doc. 12-8). On January 29, 2016, the Supreme Court of Alabama declined Bryant’s petition for a writ of certiorari. (Doc. 12-10). Bryant then filed a pro se petition for relief from conviction or sentence under Alabama Rule of Criminal Procedure 32 on April 1, 2016. In his Rule 32 petition, Bryant raised the following claims: (1) the State did not present sufficient evidence to sustain his conviction; (2) the trial court erred by allowing two witnesses to invoke the Fifth Amendment in the presence of the jury; (3) his trial counsel was ineffective

for failing to seek a curative instruction regarding the witnesses invoking the Fifth Amendment; (4) the trial court improperly admitted DNA evidence; (5) his trial counsel was ineffective for failing to object to the two witnesses invoking the Fifth Amendment in the jury’s presence; (6) his trial counsel was ineffective for failing to object to the DNA evidence admitted against him; (7) his trial counsel was ineffective for failing to hire an outside forensic expert; (8) his trial counsel was ineffective for

allowing the State’s assistants to enter the jury deliberation room; and (9) his trial counsel was ineffective for failing to seek a mistrial after the State questioned a witness about being threatened by Bryant. (Doc. 12-13, PageID.820–91). On March 22, 2017, the Mobile County Circuit Court denied Bryant’s petition without an evidentiary hearing, finding that Bryant’s claims were either procedurally barred or meritless. (Doc. 12-13, PageID.903–11). Bryant filed a motion for reconsideration, which the trial court denied. (Doc. 12-13, PageID.920). Bryant, with the assistance of counsel, then appealed to the Alabama Court of

Criminal Appeals (Doc. 12-14) raising only the following claims: (1) the trial court erred by allowing two witnesses to invoke the Fifth Amendment in the presence of the jury; (2) his trial counsel was ineffective for failing to seek a curative instruction regarding the witnesses invoking the Fifth Amendment; and (3) his trial counsel was ineffective for failing to hire an outside forensic expert. On September 1, 2017, the Court of Criminal Appeals affirmed the trial court’s decision in a memorandum opinion, reasoning that Bryant’s claims were either procedurally defaulted or

meritless. (Doc. 12-17). The Court of Criminal Appeals also noted that the claims Bryant raised in his initial Rule 32 petition but omitted from his brief on appeal “are deemed abandoned and will not be considered.” (Doc. 12-17, PageID.988). On September 29, 2017, the Court of Criminal Appeals denied Bryant’s subsequent motion for a rehearing. (Doc. 12-19). Bryant then filed a petition for a writ of certiorari in the Supreme Court of Alabama (Doc. 12-20) which was denied on November 9,

2017. (Doc. 12-21). On June 29, 2018, Bryant filed the subject 28 U.S.C. § 2254 petition with the assistance of counsel. (Doc. 5, PageID.1).

II. Legal Standards This Court’s review of Bryant’s petition is governed by the Antiterrorism and Effective Death Penalty Act (AEDPA). Under AEDPA, “the role of the federal court . . . is strictly limited.” Jones v. Walker, 496 F.3d 1216, 1226 (11th Cir. 2007).

A. Merits Review

AEDPA significantly limits the scope of federal review where the state court adjudicated a claim on the merits. Specifically, § 2254(d) provides: (d) 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 respect to any claim that was adjudicated on the merits in State court proceedings unless the adjudication of the claim - -

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
McDaniel v. Brown
558 U.S. 120 (Supreme Court, 2010)
Sidney E. Scott v. James McDonough
218 F. App'x 954 (Eleventh Circuit, 2007)
Michael Deshon Ball v. United States
271 F. App'x 880 (Eleventh Circuit, 2008)
Arthur Ghee v. Retailers National Bank
271 F. App'x 858 (Eleventh Circuit, 2008)
Oats v. Singletary
141 F.3d 1018 (Eleventh Circuit, 1998)
Smith v. Singletary
170 F.3d 1051 (Eleventh Circuit, 1999)
Bilal v. Driver
251 F.3d 1346 (Eleventh Circuit, 2001)
Larry Eugene Moon v. Frederick J. Head
285 F.3d 1301 (Eleventh Circuit, 2002)
Virgil Lee Brownlee v. Michael Haley
306 F.3d 1043 (Eleventh Circuit, 2002)
Pruitt v. Jones
348 F.3d 1355 (Eleventh Circuit, 2003)
Holly Butcher v. United States
368 F.3d 1290 (Eleventh Circuit, 2004)
Kelley v. Secretary for the Department of Corrections
377 F.3d 1317 (Eleventh Circuit, 2004)
Williams v. Allen
542 F.3d 1326 (Eleventh Circuit, 2008)
Lamarca v. Secretary, Department of Corrections
568 F.3d 929 (Eleventh Circuit, 2009)
Windom v. Secretary, Department of Corrections
578 F.3d 1227 (Eleventh Circuit, 2009)
Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)

Cite This Page — Counsel Stack

Bluebook (online)
Bryant v. Toney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bryant-v-toney-alsd-2021.