Farthing v. Forshey

District Court, S.D. Ohio·Decided August 14, 2024·No. 2:23-cv-01865·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

Steven Farthing,

Petitioner, Case No. 2:23-cv-1865

v. Judge Michael H. Watson

Jay Forshey, Warden, Noble Magistrate Judge Michael R. Merz Correctional Institution,

Respondent. OPINION AND ORDER This is a habeas corpus case under 28 U.S.C. § 2254, brought pro se by Petitioner Steven Farthing (“Petitioner”) to obtain relief from his conviction in the Fairfield County Court of Common Pleas for rape, gross sexual imposition, and corrupting another with drugs. Petition, ECF No. 4 at PAGEID # 13. It is before the Court on Petitioner’s Objections, ECF No. 23, to the Magistrate Judge’s Report and Recommendations (“R&R”), ECF No. 20, recommending dismissal of the Petition. As required by 28 U.S.C. § 636(b)(3), the Court has reviewed these proceedings de novo with particular attention to Petitioner’s specific objections. Having done so, the Court finds the Objections are not well taken, and they are OVERRULED for the following reasons. I. Ground One: Jury Misconduct by Infringement on the Privilege Against Self-Incrimination

In his First Ground for Relief, Petitioner claims his Fifth Amendment privilege to remain silent and not testify against himself was infringed by jury misconduct in that the jury held his failure to testify against him. Petitioner learned that the jury held his failure to testify against him because his trial attorney had interviewed the jury after the verdict. The issue was raised in his motion for judgment of acquittal under Ohio Rule of Criminal Procedure 29, but the trial judge did not grant that motion,1 and Petitioner did not include this claim in his direct appeal. On that basis, the Magistrate Judge recommended this

claim be denied as procedurally defaulted. R&R, ECF No. 20 at PAGEID # 1292. Petitioner objects that a failure to exhaust a state court remedy which is no longer available at the time the habeas petition is filed does not bar the habeas petition. Obj., ECF No. 23 at PAGEID # 1315 (citing Fay v. Noia, 372 U.S. 391 (1963) and Keener v. Ridenour, 594 F.2d 591 (6th Cir. 1979)). On this particular point, Fay has been overruled by Wainwright v. Sykes,

433 U.S. 72 (1977). The Magistrate Judge particularly cited Wainwright as controlling on this point. R&R, ECF No. 20 at PAGEID # 1291. Petitioner also argues that the ineffectiveness of his appellate counsel

1 Under Ohio law, a motion made in the trial court but not decided as of the time of appeal is deemed to have been denied. Kostelnik v. Helper, 96 Ohio St. 3d 1, 3 (2002) (citing State ex rel. V Cos. v. Marshall (1998), 81 Ohio St.3d 467, 469 (1998)); Pentaflex v. Express Servs., Inc., 130 Ohio App. 3d 209, 217 (2d Dist.1998); State v. Harden, 2012- Ohio-1657, ¶ 23 (Ohio App. 2d Dist. 2012). should excuse this default. Obj., ECF No. 23 at PAGEID # 1315–16. However, as the Magistrate Judge also noted, ineffective assistance of appellate counsel

will excuse a procedural default only if that claim itself is not defaulted. R&R, ECF No. 20 at PAGEID # 1287 (citing Edwards v. Carpenter, 529 U.S. 446 (2000)). Because the manner of raising a claim of ineffective assistance of appellate counsel under Ohio law is only by application for reopening the appeal, and Petitioner’s time to move for reopening had expired, Petitioner had defaulted

on his ineffective assistance of appellate counsel claim. This objection therefore lacks merit, and the Magistrate Judge correctly determined that Ground One was procedurally defaulted. II. Ground Two: Improper Exclusion of Evidence of Alternate Perpetrator and Invalidity of Ohio’s Rape Shield Law

In his Second Ground for Relief, Petitioner claims his rights under the Due Process Clause, the Confrontation Clause, and the Compulsory Process Clause were violated by exclusion of proffered evidence of an alternate perpetrator in part under the Ohio Rape Shield statute, which he asserts is unconstitutional. The Magistrate Judge concluded this claim was procedurally defaulted because it was never raised in the Ohio courts until Petitioner’s appeal from denial of his petition for post-conviction relief. When the appeals court declined to consider the issue because it had not been raised in the trial court, Petitioner, who was proceeding pro se, omitted it from his appeal to the Ohio Supreme

Court. Petitioner objects on the same basis he sought to excuse this default: page limitations by the Ohio Supreme Court in a memorandum in support of

jurisdiction. Obj., ECF No. 23 at PAGEID # 1316. The objection is overruled. As the Magistrate Judge noted, virtually every appellate court in the United States imposes a paged limit on briefing, and those limits have never been held to be unconstitutional by the Supreme Court. Petitioner admits it was his choice to omit this claim and precedent requires that

every issue presented in habeas be first presented to the state courts. O’Sullivan v. Boerckel, 526 U.S. 838 (1999). Ground Two, also, was procedurally defaulted. III. Ground Three: Ineffective Assistance of Trial Counsel Petitioner claimed in his petition for post-conviction relief that his trial attorney was ineffective by failing to present DNA and polygraph evidence at trial. The trial court held this claim was barred by Ohio’s doctrine of res judicata in

criminal cases, to wit, that a claim which could have been presented on direct appeal is barred by res judicata from being present in post-conviction. The Fifth District Court of Appeals affirmed on this basis, and the Magistrate Judge upheld this ruling as establishing a procedural default of Ground Three. R&R, ECF No. 20 at PAGEID # 1295–96.

In his Objections, Petitioner does not discuss at all the Magistrate Judge’s or the state courts’ rulings on res judicata. See Obj., ECF No. 23 at PAGEID # 1316, et seq. Instead, he argues he has submitted proof of his actual innocence, to wit, the documents attached to his Motion to Expand the Record. ECF No. 15. Magistrate Judge Merz, to whom the Magistrate Judge reference in this case was transferred on May 30, 2024, denied that Motion by Notation Order on June 5, 2024, citing Cullen v. Pinholster, 563 U.S. 170 (2011). ECF No. 192.

In the R&R, he reiterated the basis of that denial. ECF No. 20 at PAGEID # 1301. Petitioner asserts that the documents he seeks to add to the record are proof of his actual innocence and therefore excuse his procedural default of this

ground for relief. This case was tried from September 17 through September 19, 2019. State Court Record, ECF No. 9; Tr., Ex. 9-9 at PAGEID # 607. Thus, the documents sought to be added to the record existed at the time of trial and were in fact available to his trial attorney. In addition to citing them as proof of his innocence, he cites them as proof of the ineffective assistance of his trial counsel who did not move to admit them in evidence.

While the state courts and the Magistrate Judge held the ineffective assistance of trial counsel claim was barred by res judicata, they also noted that claim was rebutted by the content of the trial attorney’s affidavit in post- conviction. R&R, ECF No. 20 at PAGEID # 1295. The Court agrees. The submitted documents sought to be added to the record do not prove Petitioner’s

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Related

Fay v. Noia
372 U.S. 391 (Supreme Court, 1963)
Wainwright v. Sykes
433 U.S. 72 (Supreme Court, 1977)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Edwards v. Carpenter
529 U.S. 446 (Supreme Court, 2000)
Carr X. Johnson v. Joseph H. Havener
534 F.2d 1232 (Sixth Circuit, 1976)
Samuel Keener v. L. G. Ridenour, Warden
594 F.2d 581 (Sixth Circuit, 1979)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
United States v. Rockie Lane Hilliard
11 F.3d 618 (Sixth Circuit, 1994)
Pentaflex, Inc. v. Express Services, Inc.
719 N.E.2d 1016 (Ohio Court of Appeals, 1998)
Cullen v. Pinholster
179 L. Ed. 2d 557 (Supreme Court, 2011)
Carl Hubbard v. Randee Rewerts
98 F.4th 736 (Sixth Circuit, 2024)
State ex rel. The V Cos. v. Marshall
1998 Ohio 329 (Ohio Supreme Court, 1998)