Graham v. White

101 F.4th 1199
CourtCourt of Appeals for the Tenth Circuit
DecidedMay 17, 2024
Docket23-5069
StatusPublished
Cited by14 cases

This text of 101 F.4th 1199 (Graham v. White) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Graham v. White, 101 F.4th 1199 (10th Cir. 2024).

Opinion

Appellate Case: 23-5069 Document: 010111051595 Date Filed: 05/17/2024 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

May 17, 2024 UNITED STATES COURT OF APPEALS Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _______________________________________

KIMBERLY GRAHAM,

Petitioner - Appellee,

v. No. 23-5069

TAMIKA WHITE, Warden,

Respondent - Appellant. __________________________________________

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA (D.C. No. 4:23-CV-00164-CVE-SH) _________________________________

Jennifer L. Crabb, Assistant Attorney General, Office of the Attorney General for the State of Oklahoma (Gentner F. Drummond, Attorney General for the State of Oklahoma, with her on the briefs), Oklahoma City, Oklahoma, for Respondent-Appellant.

T. Richard O’Carroll, O’Carroll & O’Carroll, Tulsa, Oklahoma, for Petitioner-Appellee. _________________________________

Before TYMKOVICH, MATHESON, and BACHARACH , Circuit Judges. _________________________________

BACHARACH, Circuit Judge. _________________________________

This appeal addresses due process when a state district court

modifies an order after the controlling precedent changes. Here a state Appellate Case: 23-5069 Document: 010111051595 Date Filed: 05/17/2024 Page: 2

district court relied on existing precedent to vacate a defendant’s

convictions. But the state appellate court then overruled that precedent.

With this change in precedent, could the state district court modify its

prior ruling and reinstate the convictions without violating the defendant’s

right to due process? The state appeals court answered yes, but the federal

district court answered no and granted habeas relief to the defendant.

We reverse the grant of habeas relief. Regardless of whether the state

appeals court had erred, its rejection of the due process claim was at least

reasonable based on the facts and Supreme Court precedent.

Background

1. The state district court vacates the defendant’s convictions based on existing precedent.

This appeal grew out of Ms. Kimberly Graham’s state convictions for

committing first-degree manslaughter and leaving the scene of a fatal

accident. See Okla. Stat. tit. 21, § 711; Okla. Stat. tit. 47, § 10-102.1.

After the convictions became final, Ms. Graham applied for post-

conviction relief on grounds that she was a Native American and the events

took place on a reservation. While this application was pending, the

Supreme Court held in McGirt v. Oklahoma that

• Congress had not disestablished the reservation and

• the State of Oklahoma lacked jurisdiction to prosecute crimes committed by Native Americans within this reservation.

2 Appellate Case: 23-5069 Document: 010111051595 Date Filed: 05/17/2024 Page: 3

140 S. Ct. 2452, 2459 (2020). 1

But did McGirt apply to defendants (like Ms. Graham), whose

convictions had already become final? The Oklahoma Court of Criminal

Appeals initially answered yes in Bosse v. State, 484 P.3d 286 (Okla. Crim.

App. 2021). The day after Bosse took effect, 2 the state district court

granted post-conviction relief to Ms. Graham and vacated her convictions.

2. The state district court reinstates the convictions after the state appeals court changes its precedent.

The next day, the Oklahoma Court of Criminal Appeals recalled its

mandate in Bosse. Appellant’s App’x vol. 1, at 90–91. Despite recall of the

Bosse mandate, the State declined to appeal the vacatur of Ms. Graham’s

convictions. After the appeal deadline expired, the Oklahoma Court of

Criminal Appeals overruled Bosse and decided that McGirt didn’t apply

1 First-degree manslaughter is punishable in federal court under the Major Crimes Act, 18 U.S.C. § 1153(a). See United States v. Budder, 76 F.4th 1007, 1009 (10th Cir. 2023) (“Under the Major Crimes Act, 18 U.S.C. § 1153, . . . manslaughter allegedly committed by an Indian in Indian country (which includes Indian reservations . . .) in Oklahoma must be tried in federal court rather than state or tribal court.”). The charge of leaving the scene of a fatal accident is punishable in federal court under the Assimilative Crimes Act, 18 U.S.C. § 13, and the Indian Country Crimes Act, 18 U.S.C. § 1152. See United States v. Langford, 641 F.3d 1195, 1196–97 (10th Cir. 2011) (explaining that state crimes committed in Indian country are assimilated into federal law). 2 The court’s opinion could be used as authority upon issuance of the mandate or placement of the court’s seal upon filing with the clerk. Okla. Crim. App. R. 3.13(B). The mandate in Bosse was issued on April 7, 2021. See Appellant’s App’x vol. 1, at 88.

3 Appellate Case: 23-5069 Document: 010111051595 Date Filed: 05/17/2024 Page: 4

retroactively to convictions that had become final. State ex rel. Matloff v.

Wallace, 497 P.3d 686, 689 (Okla. Crim. App. 2021). 3

Given the new decision, could the state district court modify its initial

order and reinstate Ms. Graham’s convictions? The State thought so and

asked the state district court to

• rescind the initial order (vacating the convictions) and

• reinstate the convictions.

Appellant’s App’x vol. 1, at 150–60. The state district court granted these

requests. Id. at 82–85.

With the convictions reinstated, Ms. Graham asked the Oklahoma

Court of Criminal Appeals for a writ of prohibition, arguing that a liberty

interest had arisen from the order vacating her convictions. Id. at 80; see

Boutwell v. Keating, 399 F.3d 1203, 1212 (10th Cir. 2005) (“[A] liberty

3 After deciding Matloff, the Oklahoma Court of Appeals abrogated its prior opinion in Bosse and upheld the denial of post-conviction relief because McGirt no longer applied retroactively. Bosse v. State, 499 P.3d 771, 774–75 (Okla. Crim. App. 2021). 4 Appellate Case: 23-5069 Document: 010111051595 Date Filed: 05/17/2024 Page: 5

interest inherent in the Due Process Clause arises upon an inmate’s release

from confinement.”). The resulting question was whether the State could

deprive her of that liberty interest based on the state appellate court’s

change in precedent. Ms. Graham urged the state appeals court to answer

no, arguing that reinstatement of her convictions would arbitrarily deprive

her of a liberty interest.

The Oklahoma Court of Criminal Appeals disagreed with Ms. Graham

and denied her request for a writ of prohibition. Graham v. Priddy, No.

PR-2021-1332, slip op. at 4 (Okla. Crim. App. Apr. 18, 2023)

(unpublished). In denying the request, the court reasoned that

• the new precedent had prevented application of McGirt to convictions that had already become final and

• the initial order (vacating the convictions) had been “unauthorized under Oklahoma law.”

Id. at 3–4.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Parker v. Tensley
Tenth Circuit, 2026
Untitled Case
N.D. Oklahoma, 2026
Cochlin v. Harvanek
W.D. Oklahoma, 2025
Williams v. Bridges
Tenth Circuit, 2025
Verdin v. Bowen
W.D. Oklahoma, 2025
Hendrix v. Bridges
Tenth Circuit, 2025
Martinez v. Quick
121 F.4th 1247 (Tenth Circuit, 2024)
Charlton v. Harding
W.D. Oklahoma, 2024
Brewer v. Regalado
N.D. Oklahoma, 2024
Hendrix v. Bridges
N.D. Oklahoma, 2024
Lasley v. Harpe
N.D. Oklahoma, 2024
Nunley v. Harpe
N.D. Oklahoma, 2024
Blount v. Clayton
N.D. Oklahoma, 2024
Yargee v. Rogers
N.D. Oklahoma, 2024

Cite This Page — Counsel Stack

Bluebook (online)
101 F.4th 1199, Counsel Stack Legal Research, https://law.counselstack.com/opinion/graham-v-white-ca10-2024.