Cato v. Ramey

CourtDistrict Court, E.D. Missouri
DecidedFebruary 19, 2021
Docket4:20-cv-00629
StatusUnknown

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

Bluebook
Cato v. Ramey, (E.D. Mo. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

RALPH CATO, ) ) Petitioner, ) ) vs. ) Case No. 4: 20 CV 629 RWS ) EILEEN RAMEY, ) ) Respondent. )

MEMORANDUM AND ORDER

Petitioner Ralph Cato is an inmate at the Jefferson City Correctional Center in Jefferson City, Missouri. Petitioner was convicted by a jury of first-degree murder, Class B first-degree assault, and three counts of armed criminal action in the City of St. Louis, Missouri (Case Number 1322-CR3426-01). Petitioner was sentenced to life without parole, a concurrent term of thirty years, three concurrent terms of twenty years, and a concurrent term of fifteen years. Petitioner’s conviction and sentence were affirmed on appeal by the Missouri Court of Appeals on March 29, 2016. Petitioner filed a pro se post- conviction motion to vacate, set aside, or correct his judgment and sentence under Missouri’s Criminal Rule 29.15. Counsel was appointed to represent him, and petitioner filed an amended Rule 29.15 motion alleging that his trial attorney was ineffective for failing to make an offer of proof and cross-examine the decedent’s mother about the decedent’s character and for failing to advise him that he could offer to enter an Alford plea. Petitioner also argued that direct appeal counsel was ineffective for failing to appeal the trial court’s admission of a Facebook post made by petitioner. After an evidentiary hearing, the trial court denied the motion and

held that petitioner did not receive ineffective assistance of counsel. Petitioner appealed the denial of his Rule 29.15 motion on the sole ground that the motion court clearly erred when it determined that counsel was not

ineffective for failing to make an offer of proof regarding the decedent’s alleged gang membership and drug dealings. The Missouri Court of Appeals affirmed the denial of post-conviction relief in an opinion dated August 13, 2019, finding that counsel did not err by failing to make an offer of proof because vague allegations

that someone else may have committed the crime did not constitute admissible alternative perpetrator evidence and petitioner was not prejudiced because he was convicted based on evidence that he had a prior disagreement with the decedent, a

photo of petitioner with a gun in his waistband from the day of the shooting, and two eyewitness identifications. In his petition for writ of habeas corpus under 28 U.S.C. § 2254, petitioner raises the following grounds for relief:

1 Petitioner claimed that the decedent was in a gang and dealt drugs and could have been shot by a disgruntled gang member or marijuana customer.

2 1) his appellate attorney was ineffective for failing to appeal the trial court’s denial of petitioner’s proposed cross-examination of the decedent’s mother as to the character of the decedent;

2) trial counsel was ineffective for failing to make an offer of proof as to the character of the decedent;

3) appeal counsel was ineffective for failing to appeal the trial court’s admission of a Facebook photo of him with a gun in his waistband from the day of the shooting based on a lack of foundation, as opposed to the argument she made about relevance, prejudicial effect, and lack of probative value; and

4) trial counsel was ineffective for failing to advise him that he could enter an Alford plea.

Petitioner is not entitled to relief on any grounds raised in his § 2254 petition for the reasons set out below. Factual Background In affirming petitioner’s conviction and sentence, the Missouri Court of Appeals summarized the facts of his case as follows: Ralph Cato appeals his convictions of one count of first-degree murder, two counts of first-degree assault, and three counts of armed criminal action arising out of an incident in the City of St. Louis on July 16, 2013, in which Cato opened fire on a porch occupied by Kenyatia Eddy, Charles Moorehead, and Jonathon Robinson. Robinson was wounded and Moorehead died . . . .

Cato, Moorehead, and Robinson went to school together as teenagers. Cato changed schools in high school and Robinson and Cato did not see each other again until 2013 when Robinson began selling Cato marijuana. That summer, Cato wanted to purchase some marijuana from Robinson on credit, but Robinson refused and a dispute ensued that led to a fist-fight between them. Moorehead was present during the fight but did not participate. Cato 3 and Robinson bloodied each other during the fight and after it broke up, Cato threatened to get a gun. A few days later, on July 16, 2013, Robinson went to Moorehead’s house and Moorehead showed Robinson a photograph of Cato with a gun sticking out of his waistband that was posted to Cato’s Facebook account. That afternoon, Robinson and Moorehead sat out on Moorehead’s front porch with Moorehead’s cousin, Eddy, when Robinson and Eddy noticed Cato coming towards the porch with a gun. They tried to flee but Cato began firing shots, hitting Robinson and Moorehead, before Cato fled. Moorehead died from the gunshot wounds.

Cato was tried by jury. At trial, both Robinson and Eddy identified Cato as the shooter. The jury convicted him of one count of first-degree murder, two counts of first-degree assault, and three counts of armed criminal action.

[Doc. 7-7]. Standard of Review Under the Antiterrorism and Effective Death Penalty Act, federal habeas relief is available to a state prisoner “only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a); see also Williams–Bey v. Trickey, 894 F.2d 314, 317 (8th Cir. 1990). “‘Ordinarily, a federal court reviewing a state conviction in a 28 U.S.C. § 2254 proceeding may consider only those claims which the petitioner has presented to the state court in accordance with state procedural rules.’” Beaulieu v. Minnesota, 583 F.3d 570, 573 (8th Cir. 2009) (quoting Gilmore v. Armontrout, 861 F.2d 1061, 1065 (8th Cir. 1988)). If the petitioner failed to properly present the claim in state court, and no adequate non-futile remedy is currently available by which he may bring the claim in that forum, the claim is deemed procedurally 4 defaulted and cannot be reviewed by the federal habeas court “unless the [petitioner] can demonstrate cause for the default and actual prejudice as a result of the alleged violation of federal law, or demonstrate that failure to consider the claims will result in a fundamental miscarriage of justice.” Coleman v. Thompson,

501 U.S. 722, 750 (1991); see also Martinez v. Ryan, 566 U.S. 1, 10–11 (2012). Where the state court adjudicated a claim on the merits, federal habeas relief can be granted on the claim only if the state court adjudication “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,” 28 U.S.C. § 2254(d)(1); or “was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” 28 U.S.C. §

2254(d)(2); see Williams v. Taylor,

Related

Weatherford v. Bursey
429 U.S. 545 (Supreme Court, 1977)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Bell v. Cone
535 U.S. 685 (Supreme Court, 2002)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Schriro v. Landrigan
550 U.S. 465 (Supreme Court, 2007)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
Henry Lee Williams-Bey v. Myrna E. Trickey
894 F.2d 314 (Eighth Circuit, 1990)
Jackson v. Norris
651 F.3d 923 (Eighth Circuit, 2011)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
Arnold v. Dormire
675 F.3d 1082 (Eighth Circuit, 2012)
Robert Flieger v. Paul K. Delo, Superintendent
16 F.3d 878 (Eighth Circuit, 1994)
John Louis Rodriguez v. United States
17 F.3d 225 (Eighth Circuit, 1994)
Corey Earl Engelen v. United States
68 F.3d 238 (Eighth Circuit, 1995)
Johnie Cox v. Larry Norris
133 F.3d 565 (Eighth Circuit, 1998)
Mark Edward Lomholt, Sr. v. State of Iowa
327 F.3d 748 (Eighth Circuit, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
Cato v. Ramey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cato-v-ramey-moed-2021.