Gearhart v. Gastelo

District Court, N.D. California·Decided November 8, 2021·No. 3:18-cv-06017·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 KEVIN A. GEARHART, Case No. 18-cv-06017-WHO (PR)

Petitioner, 8 ORDER OF DISMISSAL v. 9

10 JOSIE GASTELO, Dkt. No. 25 Respondent. 11

12 13 INTRODUCTION 14 Petitioner Kevin Gearhart seeks federal habeas relief from his state convictions, 15 claiming that evidence was wrongly admitted, the prosecutor erred, and trial counsel 16 rendered ineffective assistance. Respondent moves to dismiss the habeas petition on the 17 grounds that the claims are procedurally defaulted because the state supreme court held 18 that they were successive and untimely, citing In re Robbins, 18 Cal. 4th 770 (1998) 19 (untimely) and In re Clark, 5 Cal. 4th 750 (1993)(successive). Gearhart contends 20 procedural default should be excused because of the equitable exception granted by 21 Martinez v. Ryan, 566 U.S. 1 (2012). Under Martinez, “[i]nadequate assistance of counsel 22 at initial-review collateral proceedings may establish cause for a prisoner’s procedural 23 default of a claim of ineffective assistance at trial.” Id. at 9. Gearhart also asserts that he 24 is innocent. 25 Gearhart does not qualify for the Martinez exception. First, Martinez applies only 26 to ineffective assistance of trial counsel claims. This means that the procedural default of 27 two claims (the wrongful admission of evidence and prosecutorial error) cannot be excused 1 only when the procedural bar was applied at the initial-review collateral proceedings. 2 Here, the bar was imposed on a second round of collateral proceedings, which Gearhart 3 pursued to exhaust his claims while the instant suit was stayed. Third, Gearhart has not 4 met the requirement to show his ineffective assistance claims are “substantial.” 5 Further, Gearhart has not shown sufficient evidence of innocence. His evidence and 6 contentions do not amount to a showing that in light of all the evidence, “it is more likely 7 than not that no reasonable juror would have convicted [the petitioner].” Schlup v. Delo, 8 513 U.S. 298, 327-28 (1995). 9 BACKGROUND 10 In 2014, Gearhart was convicted in state court of committing sex crimes against 11 children and received a sentence of 95 years to life in state prison. (Order Granting First 12 Motion to Dismiss, Dkt. No. 16 at 1.) His attempts to overturn his convictions in state 13 court were unsuccessful. This federal habeas petition followed. 14 After the first order to show cause in this suit issued, respondent moved to dismiss 15 the petition on grounds that the claims were unexhausted or procedurally defaulted or both. 16 (Dkt. No. 10.) The motion was granted and resulted in the dismissal of the procedurally 17 defaulted claims. (Dkt. No. 16.) The habeas action was stayed at Gearhart’s request so 18 that he could exhaust his remaining claims. (Dkt. No. 18.) 19 Gearhart then filed a petition in the state supreme court containing his unexhausted 20 claims, the same claims he raises in the operative federal petition. It was denied:

21 The petition for writ of habeas corpus is denied. (See In re Robbins (1998) 22 18 Cal. 4th 770, 780 [courts will not entertain habeas corpus claims that are untimely]; In re Clark (1993) 5 Cal. 4th 750, 767-769 [courts will not 23 entertain habeas corpus claims that are successive]).

24 (Second Motion to Dismiss (Second MTD), State Supreme Court Opinion, Dkt. No. 25-1 25 at 1.) After exhaustion was complete, he filed an amended petition, the action was 26 27 1 reopened, and the second order to show cause issued.1 (Dkt. No. 23.) Respondent then 2 file a second motion to dismiss all claims as procedurally defaulted, which is the subject of 3 this order. (Second MTD, Dkt. No. 25.) 4 As grounds for federal habeas relief, Gearhart alleges (i) the admission of child 5 sexual abuse accommodation syndrome (CSAAS) evidence violated his right to due 6 process; (ii) the prosecutor failed to disclose favorable evidence; and (iii) defense counsel 7 rendered ineffective assistance. (Second Order to Show Cause, Dkt. No. 23 at 2.) 8 DISCUSSION 9 i. Procedural Default 10 Respondent contends that the state court’s citations to In re Robbins and In re Clark 11 render all claims procedurally defaulted. (MTD, Dkt. No. 25 at 7-8.) Gearhart responds 12 that procedural default should be excused because of the equitable exception granted by 13 Martinez v. Ryan, 566 U.S. 1 (2012). Under Martinez, “[i]nadequate assistance of counsel 14 at initial-review collateral proceedings may establish cause for a prisoner’s procedural 15 default of a claim of ineffective assistance at trial.” Id. at 9. 16 Gearhart does not qualify for the Martinez exception. First, Martinez applies only 17 to ineffective assistance of trial counsel claims. This means that the procedural default of 18 his two other claims (the admission of CSAAS evidence and prosecutorial error) cannot be 19 excused under Martinez and will be dismissed. Second, the procedural bar a petitioner 20 seeks to excuse must have been applied at the initial-review collateral proceedings. Here, 21 the bar was imposed on a second round of collateral proceedings, which Gearhart pursued 22 to exhaust his claims while this suit was stayed. Third, Gearhart has not met the 23 requirement to show his ineffective assistance claims are “substantial.” And Gearhart has 24 not shown a fundamental miscarriage of justice. His assertion of innocence does not 25 amount to a showing that in light of all the evidence, “it is more likely than not that no 26 reasonable juror would have convicted [the petitioner].” Schlup, 513 U.S. at 327-28. 27 1 a. Procedural Default Principles 2 Federal habeas relief is unavailable if a claim is procedurally defaulted, that is, if a 3 state denied claims because a petitioner failed to comply with the state’s requirements for 4 presenting claims. Coleman v. Thompson, 501 U.S. 722, 731-32 (1991). The state’s 5 grounds for denying the claim “must be independent of the federal question and adequate 6 to support the judgment.” Id. at 729. A state procedural bar is “adequate” if it is “clear, 7 consistently applied, and well-established at the time of the petitioner’s purported default.” 8 Calderon v. U.S. Dist. Ct. (Bean), 96 F.3d 1126, 1129 (9th Cir. 1996) (quoting Wells v. 9 Maass, 28 F.3d 1005, 1010 (9th Cir. 1994)). 10 The state carries the initial burden of adequately pleading “the existence of an 11 independent and adequate state procedural ground as an affirmative defense.” Bennett v. 12 Mueller, 322 F.3d 573, 586 (9th Cir. 2003). If the state meets this requirement, the burden 13 then shifts to the petitioner “to place that defense in issue,” which the petitioner may do 14 “by asserting specific factual allegations that demonstrate the inadequacy of the state 15 procedure, including citation to authority demonstrating inconsistent application of the 16 rule.” Id. If the petitioner meets this burden, “the ultimate burden” of proving the 17 adequacy of the state bar rests with the state, which must demonstrate “that the state 18 procedural rule has been regularly and consistently applied in habeas actions.” Id. 19 To overcome a claim of procedural default, petitioner must establish either 20 (1) cause for the default, and prejudice, or (2) that failure to consider the defaulted claims 21 will result in a “fundamental miscarriage of justice.” Harris v. Reed,

Gearhart v. Gastelo, (N.D. Cal. 2021).

Gearhart v. Gastelo (Gearhart v. Gastelo) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Engle v. Isaac
456 U.S. 107 (Supreme Court, 1982)
United States v. Frady
456 U.S. 152 (Supreme Court, 1982)
Murray v. Carrier
477 U.S. 478 (Supreme Court, 1986)
Harris v. Reed
489 U.S. 255 (Supreme Court, 1989)
McCleskey v. Zant
499 U.S. 467 (Supreme Court, 1991)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
Bousley v. United States
523 U.S. 614 (Supreme Court, 1998)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Willis White v. Samuel A. Lewis
874 F.2d 599 (Ninth Circuit, 1989)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
Todd Hiivala v. Tana Wood
195 F.3d 1098 (Ninth Circuit, 1999)
Kou Lo Vang v. State of Nevada
329 F.3d 1069 (Ninth Circuit, 2003)
Mayle v. Felix
545 U.S. 644 (Supreme Court, 2005)
Trevino v. Thaler
133 S. Ct. 1911 (Supreme Court, 2013)
In Re Clark
855 P.2d 729 (California Supreme Court, 1993)