Clegg v. Warden, Lake Erie Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedJune 15, 2023
Docket2:22-cv-00503
StatusUnknown

This text of Clegg v. Warden, Lake Erie Correctional Institution (Clegg v. Warden, Lake Erie Correctional Institution) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clegg v. Warden, Lake Erie Correctional Institution, (S.D. Ohio 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

LOUIS H. CLEGG, JR.,

Petitioner, : Case No. 2:22-cv-503

- vs - District Judge James L. Graham Magistrate Judge Michael R. Merz

WARDEN, Lake Erie Correctional Institution,

: Respondent. REPORT AND RECOMMENDATIONS

This is a habeas corpus case brought pro se by Petitioner Louis Clegg pursuant to 28 U.S.C. § 2254. The case is ripe for decision on the Petition (ECF No. 6), the State Court Record (ECF No. 7) and the Return of Writ (ECF No. 8). Despite several extensions of time to do so, Petitioner has not filed a reply; his last extension expired January 26, 2023. The Magistrate Judge reference in the case was recently transferred to the undersigned to help balance the Magistrate Judge workload in the District (ECF No. 15).

Litigation History

On December 13, 2019, the Delaware County Grand Jury indicted Clegg on two counts of rape in violation of Ohio Revised Code § 2907.02(A)(1)(c). A trial jury found Clegg guilty on Count One and not guilty on Count Two and he was sentenced to imprisonment from five to seven and one- half years. Clegg appealed but the Ohio Fifth District Court of Appeals affirmed. State v Clegg, 2021-Ohio-2736 (Ohio App. 5th Dist. Aug. 9, 2021). The Supreme Court of Ohio declined to exercise jurisdiction over a subsequent appeal. State v. Clegg, 165 Ohio St.3d 1479 (2021). Clegg filed his habeas corpus case in this Court on January 28, 2022.1 He pleads one ground for relief: Ground One2: Trial counsel is ineffective for inter alia, failing to raise, elicit testimony, and argue that only available defense to his client.

Supporting Facts: Trial counsel failed to raise, elicit testimony, and argue the only viable defense available to his client, the effect of which deprived him of his constitutional right to counsel.

(Petition, ECF No. 6, PageID 288).

Nowhere in the Petition does Clegg plead what he believes that “sole viable defense” to have been. As Respondent points out, a habeas petitioner is limited to the instances of ineffective assistance of trial counsel which he has litigated in the state courts. Because Petitioner has not disagreed with this proposition or indeed filed a reply at all, this Report will analyze the case in terms of the claims made on direct appeal. In the Fifth District Court of Appeals, Clegg argued his counsel provided ineffective assistance because his request for a bill of particulars was untimely and he “failed to raise a single objection to testimony and exhibits.” (Appellant’s Brief, State Court Record, ECF No. 7, PageID 563). In particular, (1) He made no objection to the testimony of Officer Bell in which the victim’s narrative about the alleged rape was recounted; (2) He never objected to the prosecutor’s repeated use of leading questions; (3) He failed to object to admission of the SANE report which recorded a substantial amount

1 This is the date of mailing of Clegg’s Motion for Leave to Proceed in forma pauperis which is the effective date of filing the Petition (ECF No. 6, PageID 293). Houston v. Lack, 487 U.S. 266 (1988); Cook v. Stegall, 295 F.3d 517, 521 (6th Cir. 2002). 2 Labeled “Ground Four” in the Petition, but there are no pleaded Grounds One, Two, or Three. of hearsay from the victim; and (4) He failed to develop Clegg’s testimony about his perception of the victim’s level of intoxication. (Appellant’s Brief, State Court Record, ECF No. 7, Ex. 19).

When a state court decides on the merits a federal constitutional claim later presented to a federal habeas court, the federal court must defer to the state court decision unless that decision is contrary to or an objectively unreasonable application of clearly established precedent of the United States Supreme Court. 28 U.S.C. § 2254(d)(1); Harrington v. Richter, 562 U.S. 86 (2011); Brown v. Payton, 544 U.S. 133, 140 (2005); Bell v. Cone, 535 U.S. 685, 693-94 (2002); Williams (Terry) v. Taylor, 529 U.S. 362, 379 (2000). Deference is also due under 28 U.S.C. § 2254(d)(2) unless the state court decision was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceedings. Deference under § 2254(d)(1) is fully applicable to claims of ineffective assistance of trial counsel.

When the claim at issue is one for ineffective assistance of counsel, moreover, AEDPA review is “doubly deferential,” Cullen v. Pinholster, 563 U.S. 170, 190 (2011), because counsel is “strongly presumed to have rendered adequate assistance and made all significant decisions in the exercise of reasonable professional judgment,” Burt v. Titlow, 571 U.S. 12, 20 (2013)(quoting Strickland v, Washington, 466 U.S. 668, 690 (1984); internal quotation marks omitted). In such circumstances, federal courts are to afford “both the state court and the defense attorney the benefit of the doubt.”

Woods v. Etherton, 578 U.S. 113 (2016)(per curiam; unanimous), reversing Etherton v. Rivard, 800 F.3d 737 (6th Cir. 2015).

“Surmounting Strickland's high bar is never an easy task.” Padilla v. Kentucky, 559 U.S. ___, ___, 559 U.S. 356, 130 S. Ct. 1473, 1485, 176 L. Ed. 2d 284, 297(2010). An ineffective-assistance claim can function as a way to escape rules of waiver and forfeiture and raise issues not presented at trial, and so the Strickland standard must be applied with scrupulous care, lest “intrusive post-trial inquiry” threaten the integrity of the very adversary process the right to counsel is meant to serve. Strickland, 466 U.S., at 689-690, 104 S. Ct. 2052, 80 L. Ed. 2d 674. Even under de novo review, the standard for judging counsel's representation is a most deferential one. Unlike a later reviewing court, the attorney observed the relevant proceedings, knew of materials outside the record, and interacted with the client, with opposing counsel, and with the judge. It is “all too tempting” to “second-guess counsel's assistance after conviction or adverse sentence.” Id., at 689, 104 S. Ct. 2052, 80 L. Ed. 2d 674; see also Bell v. Cone, 535 U.S. 685, 702, 122 S. Ct. 1843, 152 L. Ed. 2d 914 (2002); Lockhart v. Fretwell, 506 U.S. 364, 372, 113 S. Ct. 838, 122 L. Ed. 2d 180 (1993). The question is whether an attorney's representation amounted to incompetence under “prevailing professional norms,” not whether it deviated from best practices or most common custom. Strickland, 466 U.S., at 690, 104 S. Ct. 2052, 80 L. Ed. 2d 674.

Establishing that a state court's application of Strickland was unreasonable under § 2254(d) is all the more difficult. The standards created by Strickland and § 2254(d) are both “highly deferential,” id., at 689, 104 S. Ct. 2052, 80 L. Ed. 2d 674; Lindh v.

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Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Houston v. Lack
487 U.S. 266 (Supreme Court, 1988)
Lockhart v. Fretwell
506 U.S. 364 (Supreme Court, 1993)
Lindh v. Murphy
521 U.S. 320 (Supreme Court, 1997)
Bell v. Cone
535 U.S. 685 (Supreme Court, 2002)
Brown v. Payton
544 U.S. 133 (Supreme Court, 2005)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Knowles v. Mirzayance
556 U.S. 111 (Supreme Court, 2009)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
Theodore Cook v. Jimmy Stegall, Warden
295 F.3d 517 (Sixth Circuit, 2002)
Burt v. Titlow
134 S. Ct. 10 (Supreme Court, 2013)
Timothy Etherton v. Steven Rivard
800 F.3d 737 (Sixth Circuit, 2015)
Woods v. Etherton
578 U.S. 113 (Supreme Court, 2016)
State v. Clegg
2021 Ohio 2736 (Ohio Court of Appeals, 2021)
Cullen v. Pinholster
179 L. Ed. 2d 557 (Supreme Court, 2011)

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Clegg v. Warden, Lake Erie Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clegg-v-warden-lake-erie-correctional-institution-ohsd-2023.