Centofanti v. Neven

District Court, D. Nevada·Decided October 30, 2024·No. 2:13-cv-01080·Unknown

Opinion

Alfred Paul Centofanti, Case No.: 2:13-cv-01080-JAD-BNW

Petitioner

v. Order Denying Petitioner’s Motion for Reconsideration Dwight W. Neven, et al., [ECF No. 106] Respondents

Counseled Nevada state inmate Alfred Paul Centofanti brings this habeas corpus proceeding under 28 U.S.C. § 2254 to challenge his 2005 conviction for the first-degree murder of his ex-wife. Earlier this year, I granted the respondents’ motion to dismiss grounds 2, 6, and 7 as procedurally defaulted because Centofanti failed to demonstrate cause to overcome the default.1 He now requests that I reconsider that ruling.2 But because Centofanti has not shown that the ruling was clearly erroneous or manifestly unjust, I deny his motion. Background In their motion to dismiss, the respondents argued, inter alia, that Centofanti’s grounds 2, 6 and 7 should be dismissed as unexhausted.3 In ground 2, Centofanti alleged that he was denied his Sixth and Fourteenth Amendment rights to counsel of his choice when the state court disqualified his counsel based on the state’s argument that counsel may be called as a witness to establish possible motive for the crime.4 In ground 6, Centofanti alleged that the government committed misconduct when it argued that the juror who intentionally concealed her prior felony 1 ECF No. 105. 2 ECF No. 106. 3 ECF No. 85 at 8. 4 ECF No. 74 at 24. conviction actually told the jury commissioner about her felony conviction and that her voting rights have been restored, but both of those statements were false.5 Because Centofanti did not fairly present the factual basis or legal theory of grounds 2 and 6 to the Nevada appellate courts, I found that they were unexhausted.

In ground 7, Centofanti alleges that appellate counsel rendered ineffective assistance by failing to challenge the denial of Centofanti’s counsel of choice and the prosecutor’s misconduct when responding to Centofanti’s motion for new trial.6 Centofanti presented this claim to the state appellate court during his second round of postconviction litigation and argued that he couldn’t it in his first round because he had the same counsel for his direct appeal and his first state habeas case, theorizing that his counsel had an insurmountable conflict of interest.7 The Nevada Court of Appeals found that this claim was defaulted and that the conflict didn’t provide good cause to overcome his failure to raise the claims earlier because he didn’t have a right to effective postconviction counsel.8 The state appellate court disposed of ground 7 on procedural grounds and Centofanti conceded that ground 7 is procedurally defaulted. After determining that

the claims were procedurally defaulted, I considered whether Centofanti could overcome default on grounds 2, 6, and 7.9 Centofanti argued that he could overcome the procedural default of grounds 2 and 6 because his appellate counsel rendered ineffective assistance, as asserted in ground 7.10 For

5 Id. at 57–59. 6 Id. at 60. 7 ECF No. 101 at 26. 8 ECF No. 97-31 at 3–4. 9 ECF No. 105 at 8. 10 ECF No. 101 at 19, 25. ineffective assistance of counsel (IAC) to function as cause to excuse a procedural default, however, the IAC claim itself must be exhausted before the state courts as an independent claim, and as discussed supra, Centofanti’s ineffective-assistance-of-appellate-counsel (IAAC) claim was also defaulted.11

Centofanti argued that he could overcome the default of his IAAC claim and use it as good cause for his other defaulted claims.12 He asserted that he could overcome the procedural default of his IAAC claim because he could only raise the IAAC claim in postconviction proceedings, but his postconviction counsel was also his appellate counsel and thus would have had to assert his own ineffectiveness, creating a serious conflict of interest.13 Because a prisoner does not have a constitutional right to counsel in state postconviction proceedings, ineffective assistance in those proceedings does not qualify as cause to excuse a procedural default.14 I further determined that Centofanti’s argument was foreclosed by the Supreme Court in Davila v. Davis refusing “to extend Martinez15 to allow a federal court to hear a substantial-but- procedurally-defaulted IAAC claim when a prisoner’s state postconviction counsel provides

ineffective assistance by failing to raise that claim.”16

11 ECF No. 105 at 9. 12 Id. 13 ECF No. 101 at 20. 14 Coleman v. Thompson, 501 U.S. 722, 750 (1991). 15 Under Martinez v. Ryan, 566 U.S. 1 (2012), ineffective assistance of postconviction counsel can constitute cause to excuse procedural default, but only as to claims of ineffective assistance of trial counsel. 16 Davila v. Davis, 582 U.S. 521, 525 (2017). See ECF No. 105 at 10. Centofanti also relied on the Ninth Circuit’s ruling in Manning v. Foster17 for the proposition that cause may be demonstrated as a result of a conflict of interest when the attorney ceases to be the petitioner’s agent.18 I found that reliance unpersuasive because Manning concerned a situation in which trial counsel had a conflict of interest that led him to give advice

that prevented the petitioner from seeking timely habeas relief.19 In Davila, the Supreme Court explained that habeas courts are more concerned with trial errors than with errors on appeal—the rationale for conducting a cause-and-prejudice analysis for procedurally defaulted ineffective- assistance-of-trial-counsel claims doesn’t extend to IAAC claims.20 I found that Centofanti had failed to explain why Manning’s recognition that trial counsel’s conflict of interest can create cause to overcome procedural default should be extended to his post-conviction counsel claims despite Davila’s foreclosure of that result. I determined that grounds 2, 6, and 7 are procedurally defaulted and precluded from habeas review because Centofanti failed to meet his burden of demonstrating cause to excuse procedural default based on his appellate counsel’s conflict of interest in representing Centofanti

at his postconviction proceedings.21 Discussion A district court possesses “inherent procedural power to reconsider, rescind, or modify an interlocutory order for cause seen by it to be sufficient.”22 However, reconsideration of a prior

17 Manning v. Foster, 224 F.3d 1129, 1134 (9th Cir. 2000). 18 ECF No. 101 at 20. 19 Manning, 224 F.3d at 1134–35. 20 Davila, 582 U.S. at 525. 21 ECF No. 105 at 10–11. 22 City of Los Angeles v. Santa Monica Baykeeper, 254 F.3d 882, 885 (9th Cir. 2001); see also Fed. R. Civ. P. 60. order is an extraordinary remedy “to be used sparingly in the interests of finality and conservation of judicial resources.”23 “Whether or not to grant reconsideration is committed to the sound discretion of the court.”24 Absent highly unusual circumstances, the court should grant a motion for reconsideration only if (1) it is presented with newly discovered evidence, (2)

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Centofanti v. Neven, (D. Nev. 2024).

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