Fletcher v. Perkins

CourtDistrict Court, E.D. Washington
DecidedJune 11, 2025
Docket2:23-cv-00157
StatusUnknown

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

Bluebook
Fletcher v. Perkins, (E.D. Wash. 2025).

Opinion

1 Jun 11, 2025 SEAN F. MCAVOY, CLERK 2 3 4 5 UNITED STATES DISTRICT COURT

6 EASTERN DISTRICT OF WASHINGTON 7 WILLIAM FLETCHER, No. 2:23-CV-00157-MKD

8 Petitioner, ORDER DISMISSING AMENDED 9 vs. HABEAS PETITION

10 JEFFREY PERKINS, ECF No. 20 11 Respondent. Before the Court is Petitioner William Fletcher’s pro se First Amended 12 Petition under 28 U.S.C. § 2254, ECF No. 20. The Court has reviewed the briefing 13 and the record and is fully informed. For the following reasons, the Court 14 dismisses the petition with prejudice. 15 BACKGROUND 16 A. Procedural History 17 The State of Washington charged Petitioner with one count of first-degree 18 assault for the January 7, 2019, assault of L.R. ECF No. 35-2 at 47-48. In an 19 amended information, the State alleged two aggravating circumstances: (1) 20 1 Petitioner exhibited “deliberate cruelty” toward L.R. and (2) L.R. was “particularly 2 vulnerable or incapable of resistance.” Id. at 48.

3 Defense counsel successfully moved for a psychiatric evaluation of 4 Petitioner for this assault case, as well as a prior pending assault case. ECF No. 5 35-1 at 250-51; see also ECF No. 35-2 at 31-41. Jameson C. Lontz, Ph.D.

6 evaluated Petitioner (the “2019 Evaluation”) and found that “at the time of alleged 7 offenses occurring on or around [January 7, 2019], [Petitioner] did not experience 8 reduced mental status as a result of mental disorder, notwithstanding substance 9 dependence.” ECF No. 35-2 at 32. After receiving the Dr. Lontz’s 2019

10 Evaluation, defense counsel decided not to present expert testimony or a 11 diminished capacity defense at trial. Id. at 227-29. 12 During her opening statement, defense counsel stated, “Early in the day,

13 [Petitioner] took a pill because he was not feeling well.” Id. at 252. The State later 14 called L.R. and elicited testimony from her about Petitioner’s drug and alcohol use, 15 including that he asked her for alcohol and drugs. Id. at 339-45. The trial court 16 sustained two of defense counsel’s objections to this line of inquiry. Id. at 339,

17 341. 18 After the State rested, it motioned, based on defense counsel’s mention of a 19 pill during her opening statement, “to disallow any discussion of a voluntary or

20 involuntary intoxication defense based on the fact that yesterday morning is the 1 first time any of us have ever heard about it or discussed it.” Id. at 416, 420-21. 2 The State argued that it had been led to believe that defense counsel was pursuing a

3 diminished capacity defense based on Petitioner’s alleged seizures. Id. at 420. 4 Defense counsel responded: 5 [DEFENSE COUNSEL]: Sorry, Your Honor. Okay. And Your Honor, I guess I just didn’t realize when 6 I had made that statement and talked about him having taken a pill that that would be considered involuntary 7 intoxication. It seems obvious that that was not where I was going or where Defense was going in this case. Our 8 entire time my entire defense has been . . . . It’s always been that he doesn’t remember. And so when I mentioned 9 in opening that [Petitioner] had taken a pill it was not my intent to bring up any involuntary intoxication defense. 10 My -- it was just to go towards perhaps reasons why he doesn’t remember. And if that would be something, I 11 guess, the jury would have to then weigh the evidence.

12 Id. at 422-23. 13 The court stated, “It does go toward intent, okay.” Id. at 423. To which 14 defense counsel replied, “Yes.” Id. The court construed the State’s motion as a 15 motion in limine based on lack of proper notice and limited defense counsel’s 16 questions regarding voluntary intoxication. Id. 17 An unnamed senior attorney appearing as a supervisor for defense counsel, 18 argued that the State had opened to the door to Petitioner being high based on 19 L.R.’s “allegations of changed behavior,” and asked that the defense be allowed to 20 address this. Id. at 425-28. The Court responded: 1 THE COURT: No, the Court will not do that. The Defense has not put forward that defense. They have not 2 called an expert in regards to voluntary/involuntary intoxication. So, at this time, I do not find the Defense one 3 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 -- 4 continuing this trial and doing it again, I decline to do neither. At this time, I’m going to direct the Defense to 5 limit that questioning.

6 Id. at 428. 7 Petitioner testified later that day. Id. at 434. He stated that on the morning 8 of January 7, 2019, he was feeling “[a] little different, not [himself].” Id. at 435. 9 Petitioner further stated that he remembered going to L.R.’s house and speaking 10 with her. Id. at 435-36. According to Petitioner he was thinking about grabbing 11 the Swiffer to start cleaning the floors when he began “feeling weird” and 12 experienced an “auras feeling.” Id. at 436. “The next thing [he] kn[e]w,” he was 13 being awoken by a deputy across the street from L.R.’s house. Id. 14 At the close of trial, the trial court struck defense counsel’s instruction for a 15 diminished capacity defense, “[a]s it would not be based on the evidence before the 16 [c]ourt.” Id. at 455-56. The court provided jury instructions on the aggravating 17 factors of deliberate cruelty and a victim who was particularly vulnerable or 18 incapable of resistance. Id. at 467-68. 19 The jury found Petitioner guilty of assault in the first degree and returned

20 special verdicts finding that “[Petitioner]’s conduct during the commission of the 1 crime manifest[ed] deliberate cruelty to the victim” and that “[Petitioner] kn[e]w or 2 should . . . have known that the victim was particularly vulnerable or incapable of

3 resistance.” Id. at 504. 4 At sentencing, Petitioner’s sentencing range was calculated at 178 to 236 5 months. Id. at 535. The court imposed an above-range sentence of 396 months

6 based in part on the aggravating factors of deliberate cruelty and a victim 7 particularly vulnerable or incapable of resistance. Id. at 540. 8 B. Direct Appeal 9 Petitioner, through counsel, appealed his convictions to the Washington

10 State Court of Appeals (“Court of Appeals”), asserting: (1) “[t]here was 11 insufficient evidence to support the aggravating factor of deliberate cruelty,” (2) 12 “[t]here was insufficient evidence to support the aggravating factor of particular

13 vulnerability,” (3) “[t]he trial court incorrectly believed the voluntary intoxication 14 defense was an affirmative defense,” and (4) “[t]he State’s interest in excluding 15 voluntary intoxication evidence did not outweigh [Petitioner]’s constitutional right 16 to present a defense.” ECF No. 35-1 at 24. The Court of Appeals rejected

17 Petitioner’s arguments and affirmed his conviction for first degree assault with 18 aggravating factors. Id. at 110-23. 19 Petitioner sought discretionary review by the Washington State Supreme

20 Court, raising the following issues: 1 1. Assault in the first degree necessarily contemplates violent and traumatic conduct that creates a 2 probability of death, or which causes significant serious permanent disfigurement, or which causes a significant 3 permanent loss or impairment of the function of any bodily part or organ. Does the first degree assault statute 4 necessarily contemplate all pain from no pain to the most pain up to death? 5 2. Application of the deliberate cruelty aggravator 6 requires the State to demonstrate the defendant’s criminal conduct exceeds what is normally associated with or 7 inherent within the charged crime.

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