Fletcher v. Perkins

District Court, E.D. Washington·Decided June 11, 2025·No. 2:23-cv-00157·Unknown

Opinion

Jun 11, 2025 SEAN F. MCAVOY, CLERK

WILLIAM FLETCHER, No. 2:23-CV-00157-MKD

Petitioner, ORDER DISMISSING AMENDED vs. HABEAS PETITION

JEFFREY PERKINS, ECF No. 20 Respondent. Before the Court is Petitioner William Fletcher’s pro se First Amended Petition under 28 U.S.C. § 2254, ECF No. 20. The Court has reviewed the briefing and the record and is fully informed. For the following reasons, the Court dismisses the petition with prejudice. BACKGROUND A. Procedural History The State of Washington charged Petitioner with one count of first-degree assault for the January 7, 2019, assault of L.R. ECF No. 35-2 at 47-48. In an amended information, the State alleged two aggravating circumstances: (1) Petitioner exhibited “deliberate cruelty” toward L.R. and (2) L.R. was “particularly vulnerable or incapable of resistance.” Id. at 48.

Defense counsel successfully moved for a psychiatric evaluation of Petitioner for this assault case, as well as a prior pending assault case. ECF No. 35-1 at 250-51; see also ECF No. 35-2 at 31-41. Jameson C. Lontz, Ph.D.

evaluated Petitioner (the “2019 Evaluation”) and found that “at the time of alleged offenses occurring on or around [January 7, 2019], [Petitioner] did not experience reduced mental status as a result of mental disorder, notwithstanding substance dependence.” ECF No. 35-2 at 32. After receiving the Dr. Lontz’s 2019

Evaluation, defense counsel decided not to present expert testimony or a diminished capacity defense at trial. Id. at 227-29. During her opening statement, defense counsel stated, “Early in the day,

[Petitioner] took a pill because he was not feeling well.” Id. at 252. The State later called L.R. and elicited testimony from her about Petitioner’s drug and alcohol use, including that he asked her for alcohol and drugs. Id. at 339-45. The trial court sustained two of defense counsel’s objections to this line of inquiry. Id. at 339,

341. After the State rested, it motioned, based on defense counsel’s mention of a pill during her opening statement, “to disallow any discussion of a voluntary or

involuntary intoxication defense based on the fact that yesterday morning is the first time any of us have ever heard about it or discussed it.” Id. at 416, 420-21. The State argued that it had been led to believe that defense counsel was pursuing a

diminished capacity defense based on Petitioner’s alleged seizures. Id. at 420. Defense counsel responded: [DEFENSE COUNSEL]: Sorry, Your Honor. Okay. And Your Honor, I guess I just didn’t realize when I had made that statement and talked about him having taken a pill that that would be considered involuntary intoxication. It seems obvious that that was not where I was going or where Defense was going in this case. Our entire time my entire defense has been . . . . It’s always been that he doesn’t remember. And so when I mentioned in opening that [Petitioner] had taken a pill it was not my intent to bring up any involuntary intoxication defense. My -- it was just to go towards perhaps reasons why he doesn’t remember. And if that would be something, I guess, the jury would have to then weigh the evidence.

Id. at 422-23. The court stated, “It does go toward intent, okay.” Id. at 423. To which defense counsel replied, “Yes.” Id. The court construed the State’s motion as a motion in limine based on lack of proper notice and limited defense counsel’s questions regarding voluntary intoxication. Id. An unnamed senior attorney appearing as a supervisor for defense counsel, argued that the State had opened to the door to Petitioner being high based on L.R.’s “allegations of changed behavior,” and asked that the defense be allowed to address this. Id. at 425-28. The Court responded: THE COURT: No, the Court will not do that. The Defense has not put forward that defense. They have not called an expert in regards to voluntary/involuntary intoxication. So, at this time, I do not find the Defense one is timely, nor is it prepared to be put forward in any fashion at this time. If I had a choice of continuing or the trial -- continuing this trial and doing it again, I decline to do neither. At this time, I’m going to direct the Defense to limit that questioning.

Id. at 428. Petitioner testified later that day. Id. at 434. He stated that on the morning of January 7, 2019, he was feeling “[a] little different, not [himself].” Id. at 435. Petitioner further stated that he remembered going to L.R.’s house and speaking with her. Id. at 435-36. According to Petitioner he was thinking about grabbing the Swiffer to start cleaning the floors when he began “feeling weird” and experienced an “auras feeling.” Id. at 436. “The next thing [he] kn[e]w,” he was being awoken by a deputy across the street from L.R.’s house. Id. At the close of trial, the trial court struck defense counsel’s instruction for a diminished capacity defense, “[a]s it would not be based on the evidence before the [c]ourt.” Id. at 455-56. The court provided jury instructions on the aggravating factors of deliberate cruelty and a victim who was particularly vulnerable or incapable of resistance. Id. at 467-68. The jury found Petitioner guilty of assault in the first degree and returned

special verdicts finding that “[Petitioner]’s conduct during the commission of the crime manifest[ed] deliberate cruelty to the victim” and that “[Petitioner] kn[e]w or should . . . have known that the victim was particularly vulnerable or incapable of

resistance.” Id. at 504. At sentencing, Petitioner’s sentencing range was calculated at 178 to 236 months. Id. at 535. The court imposed an above-range sentence of 396 months

based in part on the aggravating factors of deliberate cruelty and a victim particularly vulnerable or incapable of resistance. Id. at 540. B. Direct Appeal Petitioner, through counsel, appealed his convictions to the Washington

State Court of Appeals (“Court of Appeals”), asserting: (1) “[t]here was insufficient evidence to support the aggravating factor of deliberate cruelty,” (2) “[t]here was insufficient evidence to support the aggravating factor of particular

vulnerability,” (3) “[t]he trial court incorrectly believed the voluntary intoxication defense was an affirmative defense,” and (4) “[t]he State’s interest in excluding voluntary intoxication evidence did not outweigh [Petitioner]’s constitutional right to present a defense.” ECF No. 35-1 at 24. The Court of Appeals rejected

Petitioner’s arguments and affirmed his conviction for first degree assault with aggravating factors. Id. at 110-23. Petitioner sought discretionary review by the Washington State Supreme

Court, raising the following issues: 1. Assault in the first degree necessarily contemplates violent and traumatic conduct that creates a probability of death, or which causes significant serious permanent disfigurement, or which causes a significant permanent loss or impairment of the function of any bodily part or organ. Does the first degree assault statute necessarily contemplate all pain from no pain to the most pain up to death? 2. Application of the deliberate cruelty aggravator requires the State to demonstrate the defendant’s criminal conduct exceeds what is normally associated with or inherent within the charged crime. Does the Court of Appeals incorrectly hold [Petitioner]’s criminal conduct was deliberately cruel when he had a demonic look and used a blunt object, striking the victim repeatedly, with enough force to constitute first degree assault?

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