Garcia v. McDowell

CourtDistrict Court, N.D. California
DecidedMay 17, 2021
Docket5:16-cv-05301
StatusUnknown

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

Bluebook
Garcia v. McDowell, (N.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 ESEQUIEL “PAUL” GARCIA, 11 Case No. 16-05301 BLF (PR) Petitioner, 12 ORDER DENYING MOTION FOR v. STAY; DENYING MOTIONS FOR 13 APPOINTMENT OF COUNSEL; 14 NEIL MCDOWELL, Warden, G EXR TA EN NT SIN IOG N M OO FT TI IO MN E F TO OR Ffo ILur Eth TRAVERSE 15 Respondent. 16 (Docket Nos. 72, 76, 77, 79, 80)

18 Petitioner, a state prisoner proceeding pro se, filed a writ of habeas corpus pursuant 19 to 28 U.S.C. § 2254. The Court found the second amended petition, Dkt. No. 35 (“SAP”), 20 stated cognizable claims, and ordered Respondent to show cause why the petition should 21 not be granted. Dkt. No. 37. Respondent has filed an answer along with exhibits in 22 support. Dkt. Nos. 56-59. Petitioner was granted three extensions of time to file a 23 traverse. Dkt. Nos. 63, 65, 71. Before the Court is Petitioner’s motion for a stay, motions 24 for appointment of counsel, and a motion for a fourth extension of time to file his traverse. 25 Dkt. Nos. 72, 76, 79, 80. 26 27 BACKGROUND 1 Santa Clara County Superior Court of first-degree murder and aiding and abetting special 2 circumstance. SAP at 1, 2. Petitioner was sentenced on May 10, 2012, to life without the 3 possibility of parole. Id. at 1. 4 Petitioner pursued a direct appeal as well as a concurrent petition for writ of habeas 5 corpus in the state courts without success. Id. at 3-6. Thereafter, Petitioner continued to 6 pursue various post judgment remedies in the state courts and with other entities. Id. at 7- 7 42. 8 On September 15, 2016, Petitioner filed a letter, initiating this federal habeas action, 9 and five days later, a petition for writ of habeas corpus. Dkt. Nos. 1, 5. On January 20, 10 2017, the Court granted Petitioner’s motion for stay under Rhines v. Weber, 544 U.S. 269 11 (2005). Dkt. No. 22. 12 On January 16, 2019, the Court granted Petitioner’s motion to reopen the action, 13 and granted Petitioner leave to file a second amended petition. Dkt. No. 29. After two 14 extension of time, Petitioner filed a second amended petition on June 16, 2019. Dkt. No. 15 35. 16 The Court found the SAP stated the following cognizable claims for federal habeas 17 relief: (1) his rights under the Confrontation Clause was violated when the trial court 18 admitted both oral and written testimonial statements from non-testifying co-defendant, 19 Miguel Chaldez, id. at 1; (2) ineffective assistance of counsel for failure to investigate and 20 other failings, id. at 84, 119; (3-I) prosecutorial misconduct based on misrepresentation 21 and use of perjured testimony and false evidence, id. at 223, 326-329; (3-II) ineffective 22 assistance of trial and appellate counsel for failure to investigate, id. at 223, 395-398; (4) 23 juror misconduct due to outside influences and related ineffective assistance of counsel 24 claim, Dkt. No. 35-7 at 1, 27; (5) prosecutorial misconduct based on improper cross- 25 examination, id. at 52-53; (6) ineffective assistance of counsel for failing to conduct 26 reasonable pre-trial investigation into Fourth, Fifth and Sixth Amendment violations, id. at 27 81-82; (7) his conviction was based on less than proof beyond a reasonable doubt of each 1 and every element of the charged crime, id. at 175; (8) his counsel had a conflict of interest 2 that materially compromised the defense, id. at 195; (9) he was denied his right to retain 3 counsel of his choice, id. at 244; and (10) cumulative error, id. at 263. Dkt. No. 37 at 2. 4 On June 19, 2020, Respondent filed an answer along with exhibits in support. Dkt. 5 Nos. 56-59. On November 16, 2020, Petitioner filed a motion to stay this habeas action 6 due to a pending hearing in state court for a Brady/Pitchess motion for discovery. Dkt. 7 No. 72 at 3-4. Respondent filed opposition to the motion for stay, Dkt. No. 75, and 8 Petitioner filed a reply, Dkt. No. 78.1 Petitioner also filed two motions requesting 9 appointment of counsel due to COVID-19, Dkt. Nos. 76, 80, and motion for a fourth 10 extension of time to file his traverse, Dkt. No. 79. 11 12 DISCUSSION 13 A. Motion for Stay and Abeyance 14 In his motion for stay, Petitioner states that there is a pending matter in state court 15 on a Brady/Pitchess motion for habeas discovery of peace officer records and a “motion 16 for discovery file reconstruction, missing discovery (beyond file reconstruction), and 17 reasonable access to that discovery.” Dkt. No. 72 at 4. Petitioner states that if evidence of a Brady violation is found, then he may then need to move for a stay under Rhines, 544 18 U.S. 269, to essentially exhaust the new claim. Id. at 6. In opposition, Respondent asserts 19 that the request is unwarranted because all the claims in the SAP are exhausted and the 20 alleged discovery Petitioner seeks does not include Brady material. Dkt. No. 75 at 3-5. In 21 reply, Petitioner refutes that there is “no Brady evidence to disclose,” that he needs to wait 22 for a ruling from the trial judge on his discovery motion, and then time to review the actual 23 documents before he can determine whether he will be able to raise a Brady claim. Dkt. 24 No. 78 at 4, 8. 25

26 1 Petitioner filed a request for an extension of time to file a reply to Respondent’s 27 opposition which is GRANTED. Dkt. No. 77. Accordingly, the reply filed on December 23, 2020, is deemed timely filed and will be considered. 1 The United States Supreme Court has held that a district court may stay mixed 2 habeas petitions to allow the petitioner to exhaust in state court. Rhines v. Weber, 544 U.S. 3 269, 277-78 (2005). Rhines requires a petitioner to show (1) “good cause” for his failure 4 to exhaust his claims in state court; (2) that his unexhausted claims are not “plainly 5 meritless”; and (3) that he has not engaged in “intentionally dilatory litigation tactics.” Id. at 278. The district court’s discretion to stay a mixed petition is circumscribed by 6 AEDPA’s stated purposes of reducing delay in the execution of criminal sentences and 7 encouraging petitioners to seek relief in the state courts before filing their claims in federal 8 court. Id. at 277. Because the use of a stay and abeyance procedure has the potential to 9 undermine these dual purposes of AEDPA, its use is only appropriate where the district 10 court has first determined that there was good cause for the petitioner’s failure to exhaust 11 the claims in state court and that the claims are potentially meritorious. Id. 12 In Brady v. Maryland, 373 U.S. 83 (1963), the Supreme Court held that “the 13 suppression by the prosecution of evidence favorable to an accused upon request violates 14 due process where the evidence is material either to guilt or to punishment, irrespective of 15 the good faith or bad faith of the prosecution.” Id. at 87. In sum, for a Brady claim to 16 succeed, petitioner must show: (1) that the evidence at issue is favorable to the accused, 17 either because it is exculpatory or impeaching; (2) that it was suppressed by the 18 prosecution, either willfully or inadvertently; and (3) that it was material (or, put 19 differently, that prejudice ensued).2 Banks v. Dretke, 540 U.S. 668, 691 (2004); Strickler 20 v. Greene, 527 U.S. 263, 281-82 (1999). Evidence is material if “there is a reasonable 21 probability that, had the evidence been disclosed to the defense, the result of the 22 proceeding would have been different.” Cone v.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
United States v. Agurs
427 U.S. 97 (Supreme Court, 1976)
United States v. Bagley
473 U.S. 667 (Supreme Court, 1985)
Strickler v. Greene
527 U.S. 263 (Supreme Court, 1999)
Banks v. Dretke
540 U.S. 668 (Supreme Court, 2004)
Tenet v. Doe
544 U.S. 1 (Supreme Court, 2005)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Cone v. Bell
556 U.S. 449 (Supreme Court, 2009)
United States v. Kohring
637 F.3d 895 (Ninth Circuit, 2011)
Perkins v. Ramsey
18 U.S. 269 (Supreme Court, 1820)

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Bluebook (online)
Garcia v. McDowell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-mcdowell-cand-2021.