Garza v. Hutchings

CourtDistrict Court, D. Nevada
DecidedMarch 29, 2021
Docket2:18-cv-00995
StatusUnknown

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

Bluebook
Garza v. Hutchings, (D. Nev. 2021).

Opinion

1 2

5 UNITED STATES DISTRICT COURT 6 DISTRICT OF NEVADA 7 * * * 8 EDWARD GARZA, Case No. 2:18-cv-00995-GMN-BNW 9 Petitioner, 10 v. ORDER

11 BRIAN WILLIAMS, et al., 12 Respondents. 13 14 This represented habeas matter under 28 U.S.C. § 2254 by Petitioner Edward 15 Garza (“Petitioner” or “Garza”) comes before the Court on respondents’ motion to dismiss 16 (ECF No. 52) and petitioner’s motion for discovery (ECF No. 44). 17 Motion to Dismiss 18 Timeliness and Relation Back 19 Respondents first seek the dismissal of Grounds 2 and 5(c) as untimely under the 20 one-year federal limitation period in 28 U.S.C. § 2244(d). The controlling issue presented 21 by the briefing is whether these claims from Garza’s counseled second amended petition 22 relate back to a timely claim in his prior pro se amended petition. 23 A claim in an amended petition that is filed after the expiration of the one-year 24 limitation period will be timely only if the claim relates back to a timely-filed claim pursuant 25 to Rule 15(c) of the Federal Rules of Civil Procedure, on the basis that the claim arises 26 out of "the same conduct, transaction or occurrence" as the timely claim. Mayle v. Felix, 27 545 U.S. 644 (2005). In Mayle, the Supreme Court held that habeas claims in an 28 amended petition do not arise out of "the same conduct, transaction or occurrence" as 1 prior timely claims merely because the claims all challenge the same trial, conviction or 2 sentence. 545 U.S. at 655-64. Rather, under the construction of the rule approved in 3 Mayle, Rule 15(c) permits relation back of habeas claims asserted in an amended petition 4 "only when the claims added by amendment arise from the same core facts as the timely 5 filed claims, and not when the new claims depend upon events separate in ‘both time and 6 type' from the originally raised episodes." Id., at 657. In this regard, the reviewing court 7 looks to "the existence of a common ‘core of operative facts' uniting the original and newly 8 asserted claims." A claim that merely adds "a new legal theory tied to the same operative 9 facts as those initially alleged" will relate back and be timely. Id., at 659 & n.5. 10 In Grounds 2 and 5(c) in the counseled second amended petition, Garza alleges, 11 factually, inter alia, that: (1) there was a factual dispute at trial as to what happened after 12 Nye County Sheriff’s Deputies Danneker and Fancher arrived in separate vehicles at the 13 home of Garza and Janice Lujan; (2) Deputies Danneker and Fancher testified that Garza 14 pointed a gun at Fancher who then shot at Garza fourteen times; (3) Garza and Lujan 15 testified that Fancher arrived in a panic, Garza was obeying police commands, and then 16 Fancher opened fire and shot Garza three times; and (4) Detective Boruchowitz thereafter 17 failed to preserve dashcam recordings from both patrol vehicles, with Boruchowitz 18 claiming that there was no video from Danneker’s dashcam and that the Fancher 19 dashcam did not show the incident with Garza. (ECF No. 40, at 9-11 & 25-26.) 20 In Ground 1 of the earlier pro se amended petition, Garza similarly alleged, 21 factually, inter alia, that Detective Boruchowitz failed to preserve dashcam video from the 22 two deputies’ respective vehicles and that the recordings would have verified his version 23 of what happened prior to the officer-involved shooting. (See ECF No. 11, at 3-10.) 24 In Ground 2 of the second amended petition, Garza claims, legally, that he was 25 denied rights to due process, a fair trial, and to present a defense in violation of the Fifth, 26 Sixth and Fourteenth Amendments because the trial court did not give an adverse 27 inference instruction to the jury due to the unpreserved audiovisual evidence. (ECF No. 28 40, at 9 & 11.) In Ground 5(c) of the pleading, Garza claims that he was denied effective 1 assistance of appellate counsel in violation of the Sixth and Fourteenth Amendments 2 when counsel did not raise the above claim during the state direct appeal. (Id., at 25-27.) 3 In the pro se amended Ground 1, Garza claimed legally, based upon the above 4 factual allegations, that he “was denied due process of law by the State’s failure to 5 preserve and/or disclose material evidence pursuant to Brady v. Maryland, in violation of” 6 the Fifth, Sixth and Fourteenth Amendments. In Ground 6, he claimed that appellate 7 counsel was ineffective for not raising, inter alia, Ground 1. (ECF No. 11, at 3,10 & 49.) 8 The Court is persuaded that current Grounds 2 and 5(c) relate back to the earlier 9 pro se claims. The claims all are tied to a common core of operative facts – Detective 10 Boruchowitz’ failure to preserve alleged dashcam recordings from the police vehicles 11 driven by Deputies Danneker and Fancher. Current Grounds 2 and 5(c) present different 12 legal theories than the legal theory presented in particular in prior Ground 1, but these 13 different legal theories nonetheless are tied to a common core of operative facts. The 14 claims therefore relate back under Rule 15(c). See, e.g., Nguyen v. Curry, 736 F.3d 1287, 15 1296-97 (9th Cir. 2013), abrogated on other grounds by Davila v. Davis, 137 S. Ct. 2058 16 (2017) (new IAC claim for failing to raise double jeopardy claim on appeal related back to 17 earlier double jeopardy claim in original petition tied to a common core of operative facts). 18 The Court is not persuaded by respondents’ arguments to the contrary. 19 Respondents urge that while the claims share “some overlapping facts, they do not share 20 a common core of operative facts because [in particular] Ground 2 . . . centers on the trial 21 court’s failure to give an instruction—a key operative fact not present in Ground 1 of his 22 first amended petition.” (ECF No. 55, at 3, with emphasis in original.) This argument 23 misses the mark. In Nguyen, the Ninth Circuit rejected a similar argument that relation 24 back was precluded because the new claim was based on an allegedly key operative 25 fact—the attorney’s failure to raise the double jeopardy issue later on the direct appeal— 26 that was not presented in the earlier substantive claim. See 736 F.3d at 1297. The 27 relevant question is not whether the old claim requires proof of every single factual 28 element, even an arguendo “key” element, required to establish the new claim. Rather, 1 the relevant inquiry instead is whether the old and new claims are “tied” to a common 2 core of operative facts. The claims here are tied to a common core of operative facts, 3 Boruchowitz’ failure to preserve the alleged dashcam recordings.1 4 Respondents further urge that relation back is precluded because the current 5 claims allegedly depend upon events separate in both time and type from the episodes 6 raised in the earlier claim. They maintain that this is so “because Ground 1 of [Garza’s] 7 first amended petition involves the prosecutor’s failure to disclose evidence before trial, 8 whereas [in particular] Ground 2 of his untimely petition involves the trial court’s failure to 9 give an instruction to jurors during trial.” (ECF No. 55, at 3, with emphasis in original.) 10 However, Nguyen instructs that “the ‘time and type’ language in Mayle refers not to the 11 claims, or grounds for relief . . . [but, rather] . . . refers to the facts that support those 12 grounds.” 736 F.3d at 1297 (emphasis in original).

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Garza v. Hutchings, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garza-v-hutchings-nvd-2021.