Grieco v. Warden, Ohio Reformatory for Women

District Court, S.D. Ohio·Decided November 9, 2021·No. 3:21-cv-00193·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON

JESSICA LYNN GRIECO,

Petitioner, : Case No. 3:21-cv-193

- vs - District Judge Thomas M. Rose Magistrate Judge Michael R. Merz

TERI BALDAUF, Warden, Ohio Reformatory for Women,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case is before the Court for decision on the merits. The relevant pleadings are the Petition (ECF No. 4), the State Court Record (ECF No. 26), the Supplemental Record (ECF No. 35), the Warden’s Return (ECF No. 27), and Petitioner’s Traverse (ECF No. 33).

Litigation History

The July 2017 term of the Montgomery County Grand Jury indicted Grieco on one count of domestic violence in violation of Ohio Revised Code § 2919.25(B) (Count 1), one count of involuntary manslaughter in violation of Ohio Revised Code § 2903.04(A) (Count 2), and one count of reckless homicide in violation of Ohio Revised Code § 2903.041(A) (Count 3), all arising from the March 2017 shooting death of Grieco’s fiancé, Peter Underwood. All three counts carried attendant firearm specifications. (Indictment, State Court Record, ECF No. 26, Ex. 1). After motion practice, including a denied motion to suppress, and a change of counsel, on October 22, 2018, Grieco waived her former plea of not guilty and entered a plea of guilty to domestic violence (reckless/serious physical harm – one prior conviction) (Count 1) and involuntary manslaughter (Count 2). At sentencing on November 30, 2018, the Common Pleas Court merged the two counts to which Grieco pleaded guilty. The State elected to have her sentenced on the manslaughter charge and she was sentenced to eight years imprisonment. Although Grieco did not timely appeal, the Ohio Second District Court of Appeals allowed her

to file a delayed appeal and appointed counsel who filed on her behalf a brief claiming her plea was not voluntary and the trial court abused its discretion in imposing an eight-year sentence (Appellate Brief, State Court Record, ECF No. 26, Ex. 33). The Second District then affirmed the conviction. State v. Grieco, 2020-Ohio-6956 (2nd Dist. Dec. 30, 2020), appellate jurisdiction declined, 163 Ohio St. 3d 1430 (2021). On October 11, 2019, Grieco filed pro se a petition for post-conviction relief under Ohio Revised Code § 2953.21 (Petition, State Court Record, ECF No. 26, Ex. 44). On May 18, 2020, the Court of Common Pleas granted summary judgment to the State and dismissed the post-conviction petition. Id. at Ex. 51. Grieco appealed, but the Second District affirmed dismissal of the Petition. State v. Grieco, 2021-Ohio-735 (2nd Dist. Mar. 12, 2021), appellate jurisdiction declined, 2021-Ohio- 1429 (2021). On December 1, 2020, Grieco filed a Successive Petition for Post-Conviction Relief under Ohio Revised Code § 2953.21 (Successive Petition, State Court Record, ECF No. 26, Ex. 72). On January 13, 2021, Common Pleas Judge Mary Montgomery dismissed the Successive Petition, essentially on grounds the Common Pleas Court lacked jurisdiction to consider it because Grieco had not met the successive petition requirements of Ohio Revised Code § 2953.23. Id. at Ex. 82. On January 26, 2021, Grieco applied to reopen her direct appeal to raise claims of ineffective assistance of appellate counsel under Ohio R. App. P. 26(B) (Application, State Court Record, ECF No. 26, Ex. 83). The Second District denied the Application, Id. at Ex. 84, and the Supreme Court of Ohio declined to exercise appellate jurisdiction. Petitioner filed the Petition in this case by depositing it in the prison mail system on July 12, 2021. She pleads the following grounds for relief: Ground One: Prosecutors represented that Deputy Brian Godsey’s report was true, and admissible, when it was not. This was a violation of the Petitioner’s 5th and 14th Amendment right to Due Process and Equal Protection. These actions also violated Petitioner’s 6th Amendment right to a fair trial.

Supporting Facts: Deputy Brian Godsey’s report falsley [sic] stated, “A Harrison Medic gave her saline and a towel to wash her hands with.” Deputy Godsey’s own body microphone transcript proved that Deputy Godsey washed Petitioner’s hands off, then never submitted the towel as evidence Petitioner’s touch DNA was excluded from the trigger/ trigger guard of the gun involved in this case. No gun shot residue test was done on Petitioner’s hands. Petitioner has maintained that she did not pull the trigger on the gun. The victim, Peter Underwood’s touch DNA could not be excluded from the trigger/ trigger guard, slide, and stock of the gun involved in this case. The towel was both inculpatory and exculpatory evidence. Peter Underwood had threatened suicide multiple times that day via text messages, suicide note, and verbally. Petitioner has maintained that she was trying to stop him from fatally harming himself. Gunshot residue concentration can be tested to determine/ differentiate if a person had pulled the trigger, or merely touched the gun. The falsified report was presented to the Grand Jury for the purposes of obtaining an indictment; only 2 hours after Petitioner was “No True Bill” (ed).

Ground Two: Deputy Brian Godsey (Montgomery County Sheriff’s Dept.) falsified a police report that was material to the Petitioner. This violated the Petitioner’s 5th and 14th Amendment right to Due Process, her 6th Amendment right to a fair trial, her right to compulsory process, and her 6th Amendment right to present a full defense.

Supporting Facts: Deputy Brian Godsey falsely stated that, “A Harrison Township Medic gave her saline and a towel.” Deputy Godsey’s body microphone clearly shows that he told me to hang my hands out, and he washed them off with saline, and handed me a towel. Footage from Deputy Schaeublin’s cruiser camera shows medics walking out of the house, getting in their ambulance and driving away. They never approached the cruiser Ms. Grieco was in.

Ground Three: Trial Counsel was ineffective for allowing a false report, and questionable evidence to be used to leverage a legal proceeding; the results of which was unfavorable to his client. This violated the Petitioner’s 5th and 14th Amendment right to Due Process, her 6th Amendment right to effective counsel, and a fair trial.

Supporting Facts: Trial counsel Marshall Lachman, became aware of the fact the report from Deputy Godsey was falsified; once he received a copy of the transcript. The transcript was attached to the Judge’s decision overruling Ms. Grieco’s Motion to Suppress statements. Ms. Grieco also pointed it out to Mr. Lachman; yet he did nothing. Marshall abandoned advocacy for his client over state interests.

Ground Four: The misconduct and misrepresentation, as well as impermissible conduct by State agents resulted in an involuntary, and unknowing guilty plea; which was not a valid plea, as it rested upon a faulty premise. This makes the plea and sentence void and unenforceable. This violated Petitioner’s 4th Amendment right for her person to be safe from unreasonable seizure, her 5th + 14th Amendment right to Due Process, her 6th Amendment right to a fair trial, a full defense, and 8th Amendment protection against cruel and unusual punishment.

Supporting Facts: Deputy Godsey tampered evidence, didn’t submit said evidence, then falsified her report to cover up her actions. The prosecution submitted the falsified report to the Grand Jury, and the other evidence that Deputy Godsey gathered after the original tampering occurred. Judge Langer’s signature is on the ruling that contained the proof of misconduct (Exhibit B). Prosecutors, and defense counsel received copies of that ruling (Exhibit B). Yet, they continued to perpetuate these falsehoods upon the court.

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