French 827684 v. Burt

CourtDistrict Court, W.D. Michigan
DecidedSeptember 13, 2021
Docket1:17-cv-00837
StatusUnknown

This text of French 827684 v. Burt (French 827684 v. Burt) is published on Counsel Stack Legal Research, covering District Court, W.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
French 827684 v. Burt, (W.D. Mich. 2021).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ______

BENJAMIN FRENCH,

Petitioner, Case No. 1:17-cv-837

v. Honorable Gordon J. Quist

SHERRY L. BURT,

Respondent. ____________________________/

ORDER ADOPTING REPORT AND RECOMMENDATION AND DENYING PETITIONER’S HABEAS PETITION

This is a habeas corpus action brought by a state prisoner under 28 U.S.C. § 2254. United States Magistrate Judge Ray Kent has issued a Report and Recommendation (R & R), recommending that the habeas petition be denied on the merits. (ECF No. 16.) Petitioner, Benjamin French, with the assistance of counsel, filed objections. (ECF No. 17.) Upon receiving objections, the district judge “shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1). This Court may accept, reject, or modify any or all of the magistrate judge’s findings or recommendations. 28 U.S.C. §636(b)(1); Fed. R. Civ. P. 72(b). After conducting a de novo review of the report and recommendation, the objections, and the pertinent portions of the record, the Court will: (1) approve the R & R; (2) adopt the R & R, as supplemented by this order, as the opinion of the Court; (3) deny the habeas petition; and (4) deny a certificate of appealability. DISCUSSION I. Procedural Default Petitioner first objects to the magistrate judge’s determination that review of Petitioner’s claims might be barred by the doctrine of procedural default. Petitioner acknowledges that he did not raise his first two habeas issues on direct appeal but claims that his failure was not a procedural

default because he established cause and prejudice for not raising them on direct appeal. (Obj., ECF No. 17 at PageID.2722-2723.) Additionally, Petitioner claims that the Court’s failure to consider the claims would result in a fundamental miscarriage of justice. (Id. at PageID.2723.) Both arguments, however, depend on the determination that the underlying issues are meritorious. It is that very fact—that determination of procedural default requires determination of the merits— that led the magistrate judge to forego resolving any of Petitioner’s claims on the ground of procedural default in favor of addressing the merits. Thus, whether review of Petitioner’s habeas challenges might be barred on the ground of procedural default is simply immaterial to the resolution of those claims. On de novo review, the Court agrees with the magistrate judge that it is a simpler matter to review Petitioner’s claims on the merits than to resolve the procedural default

issue. II. Delayed Arraignment In Petitioner’s first habeas ground he argued that his rights to a timely arraignment and attorney assistance were violated when his “arraignment was unnecessarily delayed and access to his attorney denied so that police officers could continue their relentless interrogation until they obtained a less-than-reliable confession.” (Pet., ECF No. 1 at PageID.12.) In rejecting Petitioner’s claim, the trial court accounted for the entire period between Petitioner’s arrest and his arraignment, including each specific instance wherein Petitioner was subject to questioning by police. (Ingham Cnty. Cir. Ct. Op. & Order, ECF No. 8-27 at PageID.1913-1918.) This action is governed by the Antiterrorism and Effective Death Penalty Act of 1996, Pub. L. 104-132, 110 Stat. 1214 (AEDPA). The AEDPA “prevent[s] federal habeas ‘retrials’” and ensures that state court convictions are given effect to the extent possible under the law. Bell v. Cone, 535 U.S. 685, 693-94, 122 S. Ct. 1843, 1849-50 (2002). An application for writ of habeas corpus on behalf of a person who is incarcerated pursuant to a state conviction cannot be granted

with respect to any claim that was adjudicated on the merits in state court unless the adjudication: “(1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established federal law as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based upon an unreasonable determination of the facts in light of the evidence presented in the state court proceeding.” 28 U.S.C. § 2254(d). Petitioner says that the magistrate judge should have conducted a de novo review of the constitutional challenge to Petitioner’s interrogation. The magistrate judge declined that invitation and, instead, applying appropriate AEDPA deference, concluded that Petitioner failed to show that the trial court’s consideration of the totality of the circumstances surrounding Petitioner’s

confession was inconsistent with clearly established federal law or that the underlying factual determinations were unreasonable on the record. In Petitioner’s objection, he again asks the Court to conduct a de novo review of the trial court’s decision. Petitioner recounts the circumstances of his interrogation and claims “[t]he totality . . . actually reveals that there was a delayed arraignment in order to interrogate [Petitioner], causing his confession to be involuntary.” (Obj., ECF No. 17 at PageID.2735.) Perhaps the trial court could have been weighed the factors differently and found in favor of Petitioner. But that is not the standard. Petitioner must show that the trial court’s analysis is either premised on an unreasonable determination of the facts or is contrary to clearly established federal law. Petitioner does not attempt to make that showing. He does not identify a single fact found by the trial court that is unsupported by the record, nor does he explain how the trial court’s consideration of the totality of the circumstances runs afoul of relevant Supreme Court authority. Therefore, Petitioner’s objection to the R & R with regard to his first habeas ground is without merit. III. Ineffective Assistance of Trial Counsel When Counsel Conceded Petitioner’s Guilt of Robbery Petitioner next contends that his trial counsel rendered ineffective assistance when he essentially conceded Petitioner’s guilt of the charged crime of armed robbery during closing arguments. This claim has two distinct facets: first, that counsel acted improvidently in conceding the issues; and second, that counsel acted improvidently in making the concession without ever discussing it with Petitioner.

The R & R recounts in detail the trial court’s analysis of this claim. The magistrate judge concluded that the trial court’s determination of the issue was consistent with clearly established federal law. Petitioner contends that when counsel acknowledged that Petitioner participated in a robbery he essentially “gave away the farm.”1 According to Petitioner, when counsel acknowledged Petitioner’s involvement in the robbery, he paved the way for the jurors to conclude that Petitioner was guilty of felony murder. The trial court did not see it that way. The trial judge reasoned that counsel was stuck with Petitioner’s admissions regarding his involvement with the robbery and that counsel’s

acknowledgment of that fact was more of a tactical retreat that permitted counsel to draw clear lines distinguishing the intent necessary to find armed robbery from the intent necessary to find

1 United States v.

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French 827684 v. Burt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/french-827684-v-burt-miwd-2021.