Garcia v. Secretary, Department of Corrections (Sarasota County)

CourtDistrict Court, M.D. Florida
DecidedMarch 16, 2026
Docket8:23-cv-00095
StatusUnknown

This text of Garcia v. Secretary, Department of Corrections (Sarasota County) (Garcia v. Secretary, Department of Corrections (Sarasota County)) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garcia v. Secretary, Department of Corrections (Sarasota County), (M.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

JULIO MALACHI GARCIA,

Petitioner,

v. CASE NO. 8:23-cv-95-JLB-NHA

SECRETARY, DEPARTMENT OF CORRECTIONS,

Respondent. /

O R D E R

Before the Court is the pro se 28 U.S.C. § 2254 petition for habeas corpus relief filed by Julio Malachi Garcia (Petitioner), who is a prisoner of the Florida Department of Corrections serving a twenty-year sentence with a ten- year minimum mandatory for three counts of robbery with a firearm. (Doc. 1). At the Court’s direction (Doc. 3), Respondent filed a response (Doc. 7), and Petitioner filed a reply. (Doc. 13). Upon careful consideration of the pleadings, the state court record, and the entire file, the Court concludes that Petitioner is not entitled to federal habeas corpus relief.1

1 Because the Court was able to resolve the petition on the record, an evidentiary hearing is not warranted. See Schriro v. Landrigan, 550 U.S. 465, 474 (2007). I. BACKGROUND On the evening of November 6, 2015, Petitioner and two others, each

armed with a firearm, robbed three people at the residence of one of the victims. (Doc. 7-2 at 1036–41). A jury convicted Petitioner of three counts of robbery with a firearm (Doc. 7-2 at 978–80), and the trial court sentenced Petitioner to 20 years in prison with a ten-year minimum mandatory. (Doc.

7-2 at 1017–19. Florida’s Second District Court of Appeal (Second DCA) affirmed the conviction and sentence without a written opinion. (Doc. 7-2 at 1105). Petitioner filed a motion for postconviction relief under Rule 3.850,

Florida Rules of Criminal Procedure (Rule 3.850 Motion) (Doc. 7-2 at 1109–27), which, after an evidentiary hearing, the post-conviction court denied. (Doc. 7-2 at 1421–42). The Second DCA affirmed without a written opinion. (Doc. 7-2 at 1517).

Under the “mail-box rule,” Houston v. Lack, 487 U.S. 266, 275 (1988), Petitioner filed his pro se petition for habeas corpus relief on January 11, 2023. (Doc. 1). Respondent admits that the petition is timely (Doc. 7 at 2) but argues both that one ground alleges no federal claim and that two grounds are

unexhausted, which precludes federal review of the merits of those two grounds. A. Ground Three is Denied Because Habeas Review is Limited to a Federal Claim

In Ground Three, Petitioner alleges that the trial court erred in excluding his earlier statement about prior drug sales by state witnesses as an explanation for why he was at the residence of one of the victims. Section 2254(a) limits federal habeas corpus review to only an allegation

“that he is in custody in violation of the Constitution or laws or treaties of the United States.” As a general principle, an alleged violation of state law fails to assert a constitutional issue, as Wilson v. Corcoran, 562 U.S. 1, 5 (2010), explains:

But it is only noncompliance with federal law that renders a State’s criminal judgment susceptible to collateral attack in the federal courts. The habeas statute unambiguously provides that a federal court may issue the writ to a state prisoner “only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a). And we have repeatedly held that “‘federal habeas corpus relief does not lie for errors of state law.’” Estelle v. McGuire, 502 U.S. 62, 67, 112 S. Ct. 475, 116 L. Ed. 2d 385 (1991) (quoting Lewis v. Jeffers, 497 U.S. 764, 780, 110 S. Ct. 3092, 111 L. Ed. 2d 606 (1990)). “[I]t is not the province of a federal habeas court to reexamine state- court determinations on state-law questions.” 502 U.S., at 67–68, 112 S. Ct. 475.

In excluding Petitioner’s earlier statement about the state witnesses’ prior drug sales as an explanation for why he was at the home of one of the victims, the trial court ruled as follows: I will not allow any prior bad acts or discussions about this home, the alleged victims, the defendant, or any witness for that matter, about prior drug activity. I’ll find that that is improper evidence and not admissible in the trial related to a robbery on a specific date and time. My inclination right now is that as it goes to the Defense that it may I think in fact be relevant to explain why perhaps Mr. Garcia was there for a reason other than as the Defense states committing a robbery.

(Doc. 7-2 at 307). At trial and on direct appeal –– as well as in his federal petition –– Petitioner argued for admissibility of the evidence under the “rule of completeness” under state law. Notably, Petitioner never asserted –– and still does not assert –– that the exclusion of the evidence violated a federal right. As a general principle, an alleged violation of state law fails to assert a constitutional issue because the admissibility of evidence in state court is largely a matter for the state to decide without federal intervention. See Marshall v. Lonberger, 459 U.S. 422, 438, n.6 (1983) (“[T]he Due Process Clause does not permit the federal courts to engage in a finely tuned review of the wisdom of state evidentiary rules.”); Bradshaw v. Richey, 546 U.S. 74, 76 (2005) (“We have repeatedly held that a state court’s interpretation of state law . . . binds a federal court sitting in habeas corpus.”); Pinkney v. Sec’y, Dep’t of Corr., 876 F.3d 1290, 1299 (11th Cir. 2017) (“[I]t is not a federal court’s role to examine the propriety of a state court’s determination of state law.”); McCullough v. Singletary, 967 F.2d 530, 535–36 (11th Cir. 1992) (“A state’s interpretation of its own laws or rules provides no basis for federal habeas corpus relief, since no question of a constitutional nature is involved.”).

Ground Three fails to assert a federal claim that is entitled to a review on the merits. B. Grounds 2 and 4 are Denied as Unexhausted and Procedurally Defaulted

The Antiterrorism Effective Death Penalty Act (“AEDPA”) precludes federal courts, absent exceptional circumstances, from granting habeas relief unless a petitioner has exhausted all means of available relief under state law. 28 U.S.C. § 2254(b)(1). Exhaustion of state remedies requires that the state

prisoner “fairly presen[t] federal claims to the state courts in order to give the State the opportunity to pass upon and correct alleged violations of its prisoners’ federal rights[.]” Duncan v. Henry, 513 U.S. 364, 365 (1995). “To provide the State with the necessary ‘opportunity,’ the prisoner must ‘fairly

present’ his claim in each appropriate state court (including a state supreme court with powers of discretionary review), thereby alerting that court to the federal nature of the claim.” Baldwin v. Reese, 541 U.S. 27, 29 (2004) (citing Duncan, 513 U.S. at 365–66). The petitioner must apprise the state court of

the federal constitutional issue, not just the underlying facts of the claim or a similar state law claim. Anderson v. Harless, 459 U.S. 4, 6 (1982) (“It is not enough that all the facts necessary to support the federal claim were before the state courts, or that a somewhat similar state-law claim was made.”). Under the similar doctrine of procedural default, “a federal court will not

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Garcia v. Secretary, Department of Corrections (Sarasota County), Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-secretary-department-of-corrections-sarasota-county-flmd-2026.