Devin Lampkin v. High Desert State Prison, et al.

District Court, D. Nevada·Decided August 12, 2026·No. 2:23-cv-01997·Unknown

Opinion

Devin Lampkin, Case No.: 2:23-cv-001997-JAD-EJY

Petitioner Order Granting in Part and Denying in Part Motion to Dismiss; v. Granting Motion to Seal; and Giving Petitioner until September 14, 2026, to High Desert State Prison, et al., Notify the Court How He Will Proceed with this Mixed Petition Respondents [ECF Nos. 43, 46] Petitioner Devin Lampkin brings this habeas action under 28 U.S.C. § 22541 to challenge his 2020 state-court conviction for robbery, burglary, and conspiracy. Respondents move to dismiss Lampkin’s counseled, second amended petition as untimely, not cognizable in federal habeas, and unexhausted.2 Because I find that Ground 3 is unexhausted, I grant the motion as to that claim. But I deny the respondents’ remaining exhaustion, timeliness, and cognizability arguments and defer consideration of whether Lampkin overcomes the procedural default on Grounds 7 and 8 until the merits determination. And because this is a mixed petition, I order Lampkin to notify the court by September 14, 2026, whether he will abandon Ground 3 and proceed with his remaining grounds, dismiss the entire petition without prejudice and return to court to exhaust Ground 3, or file a motion for stay and abeyance.

1 ECF No. 35. 2 ECF No. 46. Background In November 2018, Lampkin and three co-defendants robbed a Verizon Wireless store in Las Vegas, Nevada.3 Following a ten-day trial, a jury convicted Lampkin and a co-defendant of robbery and burglary with the use of a deadly weapon and conspiracy to commit robbery.4 The

state district court sentenced Lampkin to an aggregate term of 10 to 51 years.5 The Nevada Court of Appeals affirmed his conviction.6 Lampkin filed a pro se motion for modification of his sentence in state district court, which was denied.7 He then filed a counseled state habeas petition, which was denied after an evidentiary hearing,8 and the Nevada Court of Appeals affirmed that denial.9 Lampkin then filed a pro se federal habeas petition,10 counsel was appointed, and he filed a first11 and second amended (counseled) petition asserting eight claims for relief: Ground 1: Lampkin was denied his due-process rights under the Fifth and Fourteenth Amendments because the evidence at trial was insufficient to support the convictions. A. The State’s evidence against Lampkin was extremely thin and does not amount to proof beyond a reasonable doubt. 1. Evidence of Lampkin’s refusal to exit the apartment. 2. Lampkin’s presence among known perpetrators. 3. Lampkin’s height.

3 ECF No. 40-5. 4 ECF No. 40-43. 5 ECF No. 41-7. 6 ECF Nos. 41-18, 41-35. 7 ECF Nos. 41-38, 42-1. 8 ECF Nos. 41-50, 42-5, 42-6. 9 ECF No. 42-21. 10 ECF No. 1-1. 11 ECF No. 16. 4. Clothing and instruments of offense. B. The State presented insufficient evidence for Count 7 of the indictment.

Ground 2: Lampkin was denied his due-process rights under the Fifth and Fourteenth Amendments because the trial court improperly admitted two pieces of evidence at trial, resulting in a conviction based on unduly prejudice evidence. A. Evidence of refusal to exit the apartment. B. Clothing and instruments of offense (Detective Clark’s opinion). Ground 3: Lampkin was denied his due-process rights under the Fifth and Fourteenth Amendments when the trial court failed to grant a motion to dismiss made during trial.

Ground 4: Lampkin was denied his due-process rights under the Fifth and Fourteenth Amendments when the prosecution committed prosecutorial misconduct by improperly defining the reasonable doubt standard and arguing facts not in evidence. A. The State improperly defined the reasonable doubt standard. B. The State referred to facts which were not in evidence. Ground 5: Lampkin was denied his due-process rights under the Fifth and Fourteenth Amendments because of the cumulative effect of the trial court errors.

Ground 6: Lampkin’s trial attorney provided ineffective assistance of counsel in violation of his Sixth and Fourteenth Amendment rights. A. Lampkin’s attorney failed to object or introduce evidence of the misidentification of Lampkin as the perpetrator. B. Lampkin’s attorney failed to object or introduce evidence showing Lampkin’s inability to perform certain acts allegedly identifying him as the perpetrator. Ground 7: Lampkin’s trial attorney provided ineffective assistance of counsel in violation of his Sixth and Fourteenth Amendment rights. A. Trial counsel failed to request the district court to construe a motion to dismiss Count 7 from the amended indictment as either a motion for an advisory instruction of acquittal, or as a request for judgment of acquittal upon a conviction. NRS 175.381. B. Trial counsel failed to object when the prosecution referred to facts not in evidence during closing statement. C. Trial counsel failed to interview Phillip George. Ground 8: Lampkin’s conviction and sentence are invalid under the Federal Constitutional guarantees of due process of law, equal protection, freedom from cruel and unusual punishment, the right to the effective assistance of counsel, the right to trial by a fair and impartial jury, and the right to trial by a fair and impartial tribunal because he is actually innocent of the crimes he was convicted of. U.S. Const. Amends. V, Vi, VIII and XIV.12

Respondents move to dismiss Grounds 1(B), 6(A), 7(C), and 8 as untimely, Grounds 1(B), 3, 7, and 8 as unexhausted, and Grounds 3, 5, and 8 as not cognizable on federal habeas review.13 They also argue that Lampkin failed to develop the factual basis for Grounds 6(A), 7(C), and 8.14 Discussion I. Relation Back

A new claim in an amended petition that is filed after the expiration of the Antiterrorism and Effective Death Penalty Act’s (“AEDPA’s”) one-year limitation period will be timely only if the new claim relates back to a claim in a timely-filed pleading on the basis that the claim arises out of “the same conduct, transaction or occurrence” as a claim in the timely pleading.15 Habeas claims in an amended habeas petition do not arise out of the same conduct, transaction or occurrence as claims in the original petition merely because the claims all challenge the same trial, conviction, or sentence.16 Rather, a habeas claim asserted in an amended petition relates

12 ECF No. 35. 13 ECF No. 46. 14 Id. 15 Mayle v. Felix, 545 U.S. 644, 659 (2005). 16 Id. at 655–64. back “only when the claims added by amendment arise from the same core facts as the timely filed claims, and not when the new claims depend upon events separate in ‘both time and type’ from the originally raised episodes.”17 In this regard, the reviewing court looks to “the existence of a common ‘core of operative facts’ uniting the original and newly asserted claims.”18 A claim

that merely adds “a new legal theory tied to the same operative facts as those initially alleged” will relate back and be timely.19 A. Ground 1(B) is timely. In Ground 1(B) of his second amended petition, Lampkin alleges that the State presented insufficient evidence for Count 7, a robbery charge, of the indictment.20 In Ground 5 of the timely first amended petition, Lampkin alleged that the trial court failed to grant a motion to dismiss on the basis that there was a lack of testimony as to a witness’s fear or apprehension of bodily injury as a component of the robbery charge.21 Respondents argue that Ground 1(B) does not relate back because the facts of Ground 5 focus on the trial court’s analysis of the motion to dismiss at trial.

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Devin Lampkin v. High Desert State Prison, et al., (D. Nev. 2026).

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