Derrick Cornelius Rhodes v. Vencini Smith

CourtDistrict Court, M.D. Alabama
DecidedJune 24, 2026
Docket1:25-cv-01033
StatusUnknown

This text of Derrick Cornelius Rhodes v. Vencini Smith (Derrick Cornelius Rhodes v. Vencini Smith) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Derrick Cornelius Rhodes v. Vencini Smith, (M.D. Ala. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA SOUTHERN DIVISION

DERRICK CORNELIUS RHODES, ) AIS # 219646, ) ) Petitioner, ) ) v. ) CASE NO. 1:25-CV-1033-WKW ) [WO] VENCINI SMITH, ) ) Respondent. )

MEMORANDUM OPINION AND ORDER I. INTRODUCTION In September 2025, Petitioner Derrick Cornelius Rhodes filed the instant 28 U.S.C. § 2254 petition, his first petition seeking a writ of habeas corpus. (Doc. # 1.1) Rhodes challenges the constitutionality of his convictions for two counts of first-degree rape under Alabama Code § 13A-6-61 and two counts of first-degree sodomy under Alabama Code § 13A-6-63. (See Doc. # 1.) He was convicted in 2022 after a jury trial in the Circuit Court of Houston County, Alabama, on charges for raping and sodomizing his then-ten-year-old stepdaughter in July 2012 and received a concurrent, life sentence for each conviction. (Doc. # 9-1 at 2; 9-3 at 1–

1 References to “Doc(s).” are to the document numbers of the pleadings and other materials in the court’s electronic record, as compiled and designated on the docket sheet by the Clerk of Court. Pinpoint citations are to the page of the electronically filed document in the court’s CM/ECF filing system. 2; Doc. # 14-7 at 156–57, 200; Doc. # 14-8 at 1–2.) His § 2254 petition asserts a claim alleging the denial of effective assistance of trial counsel. Rhodes argues that his trial counsel failed to discover and present evidence to the jury that he was in the

custody of the Alabama Department of Corrections (ADOC) in July 2012 and “thus was actually innocent of raping and sodomizing the victim.” (Doc. # 1 at 6.) On direct appeal and in Rule 32 post-conviction proceedings,2 the state courts denied

Rhodes relief. (Docs. # 9-1, 9-2, 9-3, 9-5, 9-7.) Respondent Vencini Smith, the warden of Donaldson Correctional Facility, answered the petition, contending that Rhodes asserts the same ineffective- assistance claim he raised in his Rule 32 proceedings and that the claim fails under

the deferential review established by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. § 2254(d). (Doc. # 9 at 1, 5–8.) Based upon a review of the parties’ submissions and for the reasons explained

below, Rhodes is not entitled to relief, and his § 2254 petition will be dismissed with prejudice. Additionally, no evidentiary hearing is necessary to resolve the petition. See Rule 8(a), Rules Governing Section 2254 Cases in the United States District Courts. Rhodes also will be denied a certificate of appealability.

2 “Rule 32 of the Alabama Rules of Criminal Procedure governs available post-conviction remedies under Alabama law.” Borden v. Allen, 646 F.3d 785, 799 n.16 (11th Cir. 2011). 2 II. SUBJECT MATTER JURISDICTION AND VENUE Under 28 U.S.C. § 2254(a), federal district courts have the authority to consider an application for a writ of habeas corpus on behalf of an individual in state

custody pursuant to a state-court judgment but “only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” This provision limits authority, rather than conferring it, with habeas jurisdiction

established by 28 U.S.C. § 2241. See Thomas v. Crosby, 371 F.3d 782, 787 (11th Cir. 2004). Under § 2241, federal district courts have the power to grant writs of habeas corpus “within their respective jurisdictions,” § 2241(a), when a state- convicted prisoner “is in custody in violation of the Constitution, ” § 2241(c)(3).

The “in-custody” requirement mandates that the habeas petitioner must “be ‘in custody’ under the conviction or sentence under attack at the time his petition is filed.” Maleng v. Cook, 490 U.S. 488, 490–91 (1989) (per curiam). Furthermore,

§ 2241(d), referred to as a “venue provision,” “gives the petitioner ‘the option of seeking habeas corpus either in the district where he is confined or the district where the sentencing court is located.’” Dobard v. Johnson, 749 F.2d 1503, 1509–10 (11th Cir. 1985) (Clark, J., dissenting) (citation omitted).

Rhodes was in custody under a state-court judgment when he filed this petition. Additionally, Rhodes was convicted and sentenced in the Circuit Court of Houston County, Alabama, and was serving his sentence in a state prison located in 3 the Middle District of Alabama. Accordingly, this court has subject matter jurisdiction to consider the petition, and venue is proper. III. BACKGROUND

A. State Court Trial Proceedings and Direct Appeal In November 2020, a grand jury convened in the Twentieth Judicial Circuit in Houston County, Alabama, and indicted Rhodes on multiple counts, including two

counts for first-degree rape under Alabama Code § 13A-6-61 and two counts for first-degree sodomy under Alabama Code § 13A-6-63. The indictments charged that between July 1, 2012, and July 31, 2012, Rhodes, who was an adult, raped and sodomized a minor who was younger than 12 years of age. (Doc. # 9-8 at 32–39.)

The minor was Rhodes’s stepdaughter, who was ten years old at the time. (Doc. # 9- 1 at 2, 6–7.) In March 2022, a jury convicted Rhodes on two counts of first-degree rape

and two counts for first-degree sodomy. He received a sentence of life for each conviction, to be served concurrently. (Doc. # 14-7 at 156–57, 200; Doc. # 14-8 at 1–2.) Rhodes timely appealed. In a memorandum decision dated February 3, 2023, the Alabama Court of Criminal Appeals (ACCA) affirmed the circuit court’s

judgment and rejected Rhodes’s “sole contention . . . that the circuit court erred in denying his motion for new trial on the basis that the verdicts [were] against the great

4 weight of the evidence.” (Doc. # 9-1, at 4–8.) A certificate of judgment was entered on June 14, 2023. (Doc. # 9-2.) B. Alabama Rule 32 Proceedings

In December 2023, Rhodes, proceeding pro se, filed a timely post-conviction petition pursuant to Rule 32 of the Alabama Rules of Criminal Procedure in the Circuit Court of Houston County (“Rule 32 petition”). (Doc. # 9-8 at 43; Doc. # 9-

3 at 2.) In March 2024, the Houston County Circuit Court summarily dismissed the Rule 32 petition. (Doc. # 9-3 at 3; see also Doc. # 9-8 at 55 (circuit court order granting the State of Alabama’s motion for summary dismissal of the Rule 32 petition).)

Rhodes appealed to the ACCA, which affirmed the circuit court’s summary- dismissal judgment. In a memorandum decision dated March 21, 2025, the ACCA summarized Rhodes’s Rule 32 petition and the State’s position as follows3:

In his petition, D.C.R. alleged that his trial counsel was ineffective because he failed to meet with D.C.R. an adequate number of times to prepare for trial and develop trial strategy. He claimed that counsel’s failure to meet with him resulted in counsel’s failure to learn that D.C.R. was incarcerated in July 2012, the time period in which the victim alleged D.C.R. assaulted her, and that counsel’s failure to learn this information and present this “viable defense” at trial “undermined” the outcome of his trial. (C. 15.) D.C.R.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Psarianos v. Standard Marine, Ltd., Inc.
12 F.3d 461 (Fifth Circuit, 1994)
James Dwight Thomas v. James Crosby
371 F.3d 782 (Eleventh Circuit, 2004)
Williams v. McNeil
557 F.3d 1287 (Eleventh Circuit, 2009)
McGahee v. Alabama Department of Corrections
560 F.3d 1252 (Eleventh Circuit, 2009)
Rhode v. Hall
582 F.3d 1273 (Eleventh Circuit, 2009)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Maleng v. Cook
490 U.S. 488 (Supreme Court, 1989)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
Borden v. Allen
646 F.3d 785 (Eleventh Circuit, 2011)
Joshua Daniel Bishop v. Warden, GDCP
726 F.3d 1243 (Eleventh Circuit, 2013)
Brown v. State
663 So. 2d 1028 (Court of Criminal Appeals of Alabama, 1995)
Marlandow Jeffries v. United States
748 F.3d 1310 (Eleventh Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Derrick Cornelius Rhodes v. Vencini Smith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/derrick-cornelius-rhodes-v-vencini-smith-almd-2026.