Edwards v. State of Nevada

CourtDistrict Court, D. Nevada
DecidedFebruary 26, 2020
Docket2:18-cv-00346
StatusUnknown

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

Bluebook
Edwards v. State of Nevada, (D. Nev. 2020).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 4 Harold Edwards, Case No. 2:18-cv-00346-JAD-BNW

5 Petitioner Order Granting Respondents’ Motion to Dismiss and to File the PSR under Seal, 6 v. Denying Petitioner’s Motion for Summary Judgment, and Setting Merits Briefing 7 State of Nevada, et al., Schedule 8 Respondents [ECF Nos. 27, 30, 40] 9 10 11 Pro se petitioner Harold Edwards pled guilty to burglary, possession of credit or debit 12 card without cardholder’s consent, and battery on a protected person after stealing a Bellagio 13 employee’s backpack from her employee locker. He was adjudicated under the large habitual- 14 criminal statute and sentenced to a term of 10–25 years in Nevada state prison. Edwards seeks a 15 writ of habeas corpus under 28 U.S.C. § 2254.1 Respondents move to dismiss grounds 1, 2, 4, 16 and 5 as either not cognizable in federal habeas or defaulted, leaving unchallenged only his 17 ineffective-assistance claims.2 They also move to seal Edwards’s presentence investigation 18 report, which is filed as Exhibit 20 to the motion to dismiss. Edwards opposes the motion to 19 dismiss,3 and he filed a motion for summary judgment.4 20 Because I find that Ground 2 alleges only a state-law error for which federal habeas relief 21 is not available, and because Grounds 1, 4, and 5 are procedurally barred, I dismiss these 22 grounds. I also seal Exhibit 20 because it contains sensitive, confidential information. I then 23 deny Edwards’s summary judgment motion because that relief is not procedurally appropriate here.

1 ECF No. 1-1. 2 ECF No. 27. 3 ECF No. 33. 4 ECF No. 40. 1 Procedural History and Background 2 Edwards pleaded guilty to burglary, five counts of possession of credit or debit card 3 without cardholder’s consent, and battery on a protected person,5 after a Bellagio employee’s 4 backpack went missing from her employee locker and surveillance tape showed Edwards 5 emerging from an employee-only area with it.6 In accordance with his guilty plea agreement, 6 Edwards was adjudicated under the large habitual-criminal statute, and the state district court 7 sentenced him to a term of 10–25 years in prison.7 The judgment of conviction was filed on 8 December 21, 2016.8 9 Edwards initially appealed, but he then filed a notice of withdrawal of appeal.9 The 10 Nevada Supreme Court ordered the appeal dismissed.10 Ultimately, the Nevada Supreme Court 11 affirmed the denial of his state postconviction habeas corpus petition.11 In February 2018, 12 Edwards dispatched his federal habeas petition for filing.12 13 Discussion 14 I. Motion to Dismiss Grounds 1, 2, 4, and 5 [ECF No. 27] 15 A. Ground 2 is a state-law claim that is not cognizable in federal habeas. 16 A state prisoner is entitled to federal habeas relief only if he is being held in custody in 17 violation of the constitution, laws, or treaties of the United States.13 Unless an issue of federal 18 constitutional or statutory law is implicated by the facts presented, the claim is not cognizable 19 20 5 Exh 18. Exhibits referenced in this order are exhibits to respondents’ motion to dismiss, ECF 21 No. 27, and are found at ECF Nos. 28–29. 22 6 Exh. 3. 23 7 Exh. 25. 8 Exh. 30. 9 Exhs. 26, 35. 10 Exh. 36. 11 Exh. 57. 12 ECF No. 3. 13 28 U.S.C. § 2254(a). 1 under federal habeas corpus.14 A petitioner may not transform a state-law issue into a federal 2 one merely by asserting a violation of due process.15 Alleged errors in the interpretation or 3 application of state law do not warrant habeas relief.16 4 In Ground 2, Edwards asserts that the state district court abused its discretion when it 5 denied his motion to withdraw his guilty plea.17 Respondents argue that this is a state-law claim 6 only.18 They also point out that Edwards does not even identify a constitutional right impacted 7 by these factual allegations. Indeed, Ground 2 alleges an error only in the application of Nevada 8 state law. Therefore, I dismiss Ground 2 for failure to state a claim for which federal habeas 9 relief may be granted. 10 B. Grounds 1, 4, and 5 are barred. 11 28 U.S.C. § 2254(d), a provision of the Antiterrorism and Effective Death Penalty Act 12 (AEDPA), authorizes this court to grant habeas relief if the relevant state court decision was 13 either: (1) contrary to clearly established federal law as determined by the Supreme Court or (2) 14 involved an unreasonable application of clearly established federal law as determined by the 15 Supreme Court. A federal court will not review a claim for habeas relief if the state-court 16 decision rested on a procedural state-law ground that is independent of the federal question and 17 adequate to support the judgment19 “unless the prisoner can demonstrate cause for the default 18 and actual prejudice” from “the alleged violation of federal law, or demonstrate that failure to 19 consider the claims will result in a fundamental miscarriage of justice.”20 The procedural-default 20 21 22

23 14 Estelle v. McGuire, 502 U.S. 62, 68 (1991). 15 Langford v. Day, 110 F.3d 1380, 1381 (9th Cir. 1996). 16 Hubbart v. Knapp, 379 F.3d 773, 779–80 (9th Cir. 2004). 17 ECF No. 3 at 23–25. 18 ECF No. 27 at 6. 19 Coleman v. Thompson, 501 U.S. 722, 730–31 (1991). 20 Coleman, 501 U.S. at 750; see also Murray v. Carrier, 477 U.S. 478, 485 (1986). 1 doctrine ensures that the state’s interest in correcting its own mistakes is respected in all federal 2 habeas cases.21 3 To demonstrate cause for a procedural default, the petitioner must be able to “show that 4 some objective factor external to the defense impeded” his efforts to comply with the state 5 procedural rule.22 For cause to exist, the external impediment must have prevented the petitioner 6 from raising the claim.23 To demonstrate a fundamental miscarriage of justice, a petitioner must 7 show that the constitutional error complained of probably resulted in the conviction of an 8 actually innocent person.24 This is a narrow exception, and it is reserved for extraordinary cases 9 only.25 Bare allegations unsupplemented by evidence do not tend to establish actual innocence 10 sufficient to overcome a procedural default.26 11 All of Edwards’s claims in Grounds 1, 4, and 5 are procedurally barred. In Ground 1, 12 Edwards argues that the court failed to comply with the requirements of the large habitual 13 criminal statute at sentencing in violation of his Fourteenth Amendment due-process rights.27 In 14 Ground 4, he contends that the prosecutor committed misconduct when he retaliated against 15 Edwards by proffering a plea deal that was less favorable to Edwards than an initial global plea 16 deal involving another case that Edwards rejected.28 And in Ground 5, Edwards asserts that his 17 adjudication as a habitual criminal was so disproportionate to the offense that it constitutes cruel 18 and unusual punishment in violation of the Eighth Amendment.29 Edwards withdrew his direct 19 20 21 See Koerner v. Grigas, 328 F.3d 1039, 1046 (9th Cir. 2003). 21 22 Murray, 477 U.S. at 488 (emphasis added). 22 23 See McCleskey v.

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Edwards v. State of Nevada, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edwards-v-state-of-nevada-nvd-2020.