Crabtree v. Gittere

District Court, D. Nevada·Decided December 14, 2023·No. 3:19-cv-00479·Unknown

Opinion

* * *

ZACKERY CRABTREE, Case No. 3:19-cv-00479-LRH-CLB

Petitioner, v. ORDER

WILLIAM GITTERE, et al.,

Respondents.

This case is a pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254 brought by Zackery Crabtree, a prisoner held in custody by the Nevada Department of Corrections. For the reasons set forth herein, the court will deny Crabree’s habeas petition. Under a guilty plea agreement consolidating two criminal cases, Crabtree was convicted in the Fifth Judicial District Court for Nevada of invasion of the home and attempted battery by a prisoner. The court sentenced him to consecutive terms totaling 67 to 168 months and entered a judgment of conviction on September 27, 2016. Crabtree’s attempts at a direct appeal were dismissed as untimely. In June 2017, Crabtree filed a post-conviction petition for a writ of habeas corpus in the state district court. Prior to the state district court ruling upon his post-conviction petition, Crabtree filed motions to modify his sentence and to withdraw his guilty plea. in December 2017. Then, in June 2018, the state district court denied Crabtree’s post- conviction petition. Crabtree appealed. In June 2019, the Nevada Supreme Court entered an order affirming the lower court’s judgment denying post-conviction relief. In August 2019, Crabtree initiated this federal habeas corpus proceeding. In January 2020, he filed an amended petition raising three grounds for relief. In response to the petition, respondents filed a motion to dismiss arguing that all three grounds were unexhausted. The court agreed with respect to Grounds 1 and 3 (but not Ground 2) and gave Crabtree the option of either abandoning the unexhausted claims or requesting a stay while he returned to state court to exhaust his unexhausted claims. He chose the latter and respondents did not oppose. Consequently, the court entered an order imposing a stay, and Crabtree filed a second habeas petition in state court. The state district court entered an order erroneously stating that the state court need not act on the petition because Crabtree had a case pending in federal court. Crabtree petitioned the Nevada Supreme Court for a writ of mandamus, which the court denied because Crabtree had neglected to attach a copy of the petition for writ of habeas corpus that he had filed in the lower court. In May 2022, this court granted Crabtree’s request to reopen these proceedings. In August 2022, respondents filed a motion to dismiss. In deciding the motion to dismiss, the court concluded that Grounds 1 and 3 of Crabtree’s petition are technically exhausted, but procedurally defaulted because they would be procedurally barred by the state courts. The court reserved judgment as to whether the procedural default should be excused. Respondents then filed an answer to all three grounds in the petition. The time allotted for Crabtree to file a reply has elapsed. Thus, the case is ready for a decision on the merits. Where a petitioner has procedurally defaulted his claims, federal review is barred unless he “can demonstrate cause for the default and actual prejudice as a result of the result in a fundamental miscarriage of justice.” Coleman v. Thompson, 501 U.S. 722, 750 (1991). If a state court has adjudicated a habeas corpus claim on its merits, a federal district court may only grant habeas relief with respect to that claim if the state court's 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” or “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). A state court acts contrary to clearly established federal law if it applies a rule contradicting the relevant holdings or reaches a different conclusion on materially indistinguishable facts. Price v. Vincent, 538 U.S. 634, 640 (2003). And a state court unreasonably applies clearly established federal law if it engages in an objectively unreasonable application of the correct governing legal rule to the facts at hand. White v. Woodall, 134 S. Ct. 1697, 1705–07 (2014). As “a condition for obtaining habeas relief,” a petitioner must show that the state-court decision “was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility of fairminded disagreement.” Harrington v. Richter, 562 U.S. 86, 103 (2011). A. Grounds 1 and 3 In Ground 1, Crabtree claims that his state court conviction and sentence violate his right to due process under the Fifth and Fourteenth Amendment because his guilty plea was the product of an illegal agreement involving substantial assistance benefits. In Ground 3 claim, he claims that his sentence constitutes cruel and unusual punishment in violation of the Eighth Amendment. As noted above, these claims are both procedurally defaulted. In its order deciding respondents’ motion to dismiss, the court advised Crabtree that he could argue grounds for excusing the procedural defaults when he filed his reply 1 and 2 are dismissed as procedurally defaulted. See Coleman, 501 U.S. at 750. B. Ground 2 In Ground 2, Crabtree alleges that he was deprived of effective assistance of counsel in violation of his constitutional rights because his counsel failed to enforce an agreement that he would be granted probation if he provided substantial assistance to law enforcement. The right to counsel embodied in the Sixth Amendment provides “the right to the effective assistance of counsel.” Strickland v. Washington, 466 U.S. 668, 686 (1984) (quoting McMann v. Richardson, 397 U.S. 759, 771 n.14 (1970)). In Strickland, the United States Supreme Court held that an ineffective-assistance claim requires a petitioner to show that: (1) his counsel's representation fell below an objective standard of reasonableness under prevailing professional norms in light of all of the circumstances of the particular case; and (2) it is reasonably probable that, but for counsel's errors, the result of the proceeding would have been different. Strickland, 466 U.S. at 690, 694. When an ineffective assistance of counsel claim bears on a defendant’s decision to enter a guilty plea, the petitioner must demonstrate that “there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 59 (1985) (citations omitted). In affirming the state district court’s denial of Crabtree’s petition for writ of habeas corpus, the Nevada Court of Appeals cited the correct federal standards and held as follows:

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Related

McMann v. Richardson
397 U.S. 759 (Supreme Court, 1970)
Barefoot v. Estelle
463 U.S. 880 (Supreme Court, 1983)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Price, Warden v. Vincent
538 U.S. 634 (Supreme Court, 2003)
Schriro v. Landrigan
550 U.S. 465 (Supreme Court, 2007)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
White v. Woodall
134 S. Ct. 1697 (Supreme Court, 2014)