Columbia v. Mark Inch

CourtDistrict Court, M.D. Florida
DecidedAugust 3, 2022
Docket2:21-cv-00773
StatusUnknown

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

Bluebook
Columbia v. Mark Inch, (M.D. Fla. 2022).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION

JOHN RUSSELL COLUMBIA,

Petitioner,

v. Case No: 2:21-cv-773-JES-NPM

MARK S. INCH,

Respondent.

OPINION AND ORDER Before the Court are John Russell Columbia’s Amended Petition Under 28 U.S.C. § 2254 for Writ of Habeas Corpus by a Person in State Custody (Doc. #13), Motion for Stay and Abeyance to Exhaust State Remedies (Doc. #17), and Motion for Leave to Amend 2254 Petition (Doc. #19). Columbia challenges his conviction for eight counts of sexual battery and sexual activity with a child. I. Background Columbia was married to Terrie Taylor for seven years. Columbia and Taylor lived in a house with Taylor’s daughter, N.B. They split in 2013, and Taylor and N.B. moved out of the house. N.B. then told Taylor that Columbia had sex with her when she was 11 and 12 years old. Taylor reported the accusation to the police, who launched an investigation. (Doc. #16-2 at 208-14). On June 18, 2013, Detective Frank Pilarski had N.B. conduct a controlled phone call with Columbia. (Id. at 229-30). Columbia made many incriminating statements during the call. (See id. at 203-71). Police arrested him later that day. (Id. at 21).

In July 2013, Taylor petitioned a state court for a restraining order against Columbia. During the hearing, the judge authorized Taylor to enter Columbia’s house to recover personal belongings. Among the items Taylor retrieved was a box of Halloween decorations from the master bedroom closet. About two weeks later, Taylor opened the box and found small videocassettes and a digital camera memory card. They contained nude pictures of N.B. and recordings of Columbia having sex with N.B. (Id. at 214-17). At trial, N.B. confirmed that the video tapes accurately depicted Columbia touching her vagina with his mouth and penis. (Id. at 191-96). On August 23, 2013, Florida Circuit Judge Christine Greider

issued a search warrant allowing police to search the videocassettes and SD card. (Id. at 18-19). On September 20, 2013, the State of Florida charged Columbia with 178 counts of sexual battery of a child less than 12 years of age, sexual activity with a child, use of a child in a sexual performance, and possession of child pornography. (Id. at 26-48). The trial court severed eight counts of sexual battery and sexual activity with a child for trial. (Id. at 50). A jury found Columbia guilty on all eight counts. (Id. at 366-69). The trial court imposed six life sentences and two 30-year terms of imprisonment. (Id. at 375-95). Attorney Joshua Faett represented Columbia from pre-trial proceedings through

sentencing. On appeal, Assistant Public Defender William Sharwell found no meritorious arguments and filed an Anders 1 brief. (Id. at 419-40). The Second District Court of Appeal of Florida (2nd DCA) affirmed the conviction without a written opinion. Columbia v. State, 256 So. 3d 137 (Fla. 2d DCA 2017). Columbia filed a petition alleging Sharwell provided ineffective assistance of counsel because he did not raise a double jeopardy argument. (Doc. #16-2 at 444-92). The Second DCA denied the petition without explanation. (Id. at 494). Columbia filed a Motion for Postconviction Relief under Florida Rule of Criminal Procedure 3.850, which he amended

twice. (Id. at 735-84). The postconviction court summarily denied the motion. (Id. at 886-96). Columbia appealed. (Id. at 1074-1155). The 2nd DCA affirmed, Columbia v. State, 325 So. 3d 1273 (Fla. 2d DCA 2021) and issued its mandate on October 19, 2021 (Doc. #16-2 at 1157). Columbia filed his federal habeas Petition with one day remaining on the one-year AEDPA limitations period. After Respondent argued Grounds 1, 3, and 4 are unexhausted and

1 Anders v. California, 386 U.S. 738 (1967). procedurally barred, Columbia filed a Motion for Stay and Abeyance to Exhaust State Remedies (Doc. #17). The Court denies the request because—as the Court’s analysis will show—each of

Columbia’s grounds are plainly meritless. Giving Columbia time to raise them in state court would be futile. Columbia also requests leave to amend Grounds 1 and 2, which assert Fourth Amendment violations. (Doc. #19). Columbia wants to amend them to allege his trial counsel provided ineffective assistance by failing to contest those violations. As explained below, Columbia’s Fourth Amendment rights were not violated, so his counsel did not perform deficiently. The Court thus denies the motion to amend because amendment would be futile. II. Applicable Habeas Law a. AEDPA

The Antiterrorism Effective Death Penalty Act (AEDPA) governs a state prisoner’s petition for habeas corpus relief. 28 U.S.C. § 2254. Relief may only be granted on a claim adjudicated on the merits in state court if the adjudication: (1) 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; or (2) resulted in a decision that 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). This standard is both mandatory and difficult to meet. White v. Woodall, 134 S. Ct. 1697, 1702 (2014). A state court’s violation of state law is not enough to show that a petitioner is in custody in violation of the

“Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a); Wilson v. Corcoran, 562 U.S. 1, 16 (2010). b. Exhaustion and Procedural Default AEDPA precludes federal courts, absent exceptional circumstances, from granting habeas relief unless a petitioner has exhausted all means of relief available under state law. Failure to exhaust occurs “when a petitioner has not ‘fairly presented’ every issue raised in his federal petition to the state’s highest court, either on direct appeal or on collateral review.” Pope v. Sec’y for Dep’t of Corr., 680 F.3d 1271, 1284 (11th Cir. 2012) (quoting Mason v. Allen, 605 F.3d 1114, 1119 (11th Cir. 2010)). The petitioner must apprise the state court

of the federal constitutional issue, not just the underlying facts of the claim or a similar state law claim. Snowden v. Singletary, 135 F.3d 732, 735 (11th Cir. 1998). Procedural defaults generally arise in two ways: (1) where the state court correctly applies a procedural default principle of state law to arrive at the conclusion that the petitioner’s federal claims are barred; or (2) where the petitioner never raised the claim in state court, and it is obvious that the state court would hold it to be procedurally barred if it were raised now.

Cortes v. Gladish, 216 F. App’x 897, 899 (11th Cir. 2007). A federal habeas court may consider a procedurally barred claim if (1) petitioner shows “adequate cause and actual prejudice,” or (2) “the failure to consider the claim would result in a

fundamental miscarriage of justice.” Id. (citing Coleman v. Thompson, 501 U.S. 722, 749-50 (1991)). Another gateway through a procedural bar exists for claims of ineffective assistance of trial counsel.

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Columbia v. Mark Inch, Counsel Stack Legal Research, https://law.counselstack.com/opinion/columbia-v-mark-inch-flmd-2022.