Hammell v. Warden

2004 DNH 129
CourtDistrict Court, D. New Hampshire
DecidedAugust 31, 2004
DocketCV-03-422-SM
StatusPublished

This text of 2004 DNH 129 (Hammell v. Warden) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hammell v. Warden, 2004 DNH 129 (D.N.H. 2004).

Opinion

Hammell v . Warden CV-03-422-SM 08/31/04 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Brian R. Hammell, Petitioner

v. Civil N o . 03-422-SM Opinion N o . 2004 DNH 129 Bruce W . Cattell, Warden, Respondent

O R D E R

Brian R. Hammell, a state prisoner serving concurrent

sentences resulting from convictions on nine counts of being a

felon in possession of a weapon, petitions for a writ of habeas

corpus. 18 U.S.C. § 2254. After preliminary review by the

Magistrate Judge, Hammell’s petition consists of seven claims.1

Before the court are cross motions for summary judgment. For the

reasons given, respondent’s motion for summary judgment is

granted and petitioner’s motion for summary judgment is denied.

The historical and procedural background to Hammell’s

petition is set out in detail in the Magistrate Judge’s report

1 Two claims were dismissed for lack of subject-matter jurisdiction because they alleged only violations of state law. and recommendation (document n o . 4 ) . In brief, Hammell was

arrested by police officers who responded to a 911 call from an

apartment he occupied with his wife, Sheila, and Dan Mathieu.

When the officers arrived, they found Hammell and his wife, both

bleeding. Mathieu was also present, as were thirty-six assorted

firearms and four knives. Hammell was initially arrested for

simple assault, after he pushed one of the police officers.

Subsequently, he was charged with forty counts of being a felon

in possession of a weapon. Hammell was tried in the New

Hampshire Superior Court and convicted on the assault charge and

twelve of the forty felon-in-possession counts.2 Three of the

felon-in-possession counts were reversed, on direct appeal, by

the New Hampshire Supreme Court.3 Hammell, 147 N.H. at 320.

Here, Hammell challenges those remaining convictions on seven

separate grounds, discussed in more detail below.

2 Specifically, he was found guilty of “four counts of possessing a knife; five counts of possessing a twenty-two caliber weapon; and three counts of possessing a forty-five caliber weapon.” State v . Hammell, 147 N.H. 313, 319 (2001). 3 The three reversed convictions were related to the .45- caliber weapons.

2 Passage of the Anti-Terrorism and Effective Death Penalty

Act of 1996 (“ADEPA”), 28 U.S.C. § 2254(d), has significantly

limited the power of the federal courts to grant habeas corpus

relief to state prisoners. A federal court may disturb a state

conviction only when: (1) the state court adjudication “resulted

in a decision that was based on an unreasonable determination of

the facts in light of the evidence presented in the State court

proceeding,” 28 U.S.C. § 2254(d)(2); or (2) the state court’s

resolution of the issues before it “resulted in a decision that

was contrary t o , or involved an unreasonable application o f ,

clearly established Federal law, as determined by the Supreme

Court of the United States,” 28 U.S.C. § 2254(d)(1); see also

Williams v . Taylor, 529 U.S. 3 6 2 , 399 (2000). Regarding the

distinction between decisions “contrary to” clearly established

federal law and those involving an “unreasonable application” of

federal law, the United States Supreme Court has stated:

Under the “contrary to” clause, a federal habeas court may grant the writ if the state court arrives at a conclusion opposite to that reached by [the Supreme] Court on a question of law or if the state court decides a case differently than [the Supreme] Court has on a set of materially indistinguishable facts. Under the “unreasonable application” clause, a federal habeas court may grant the writ if the state court identifies the correct governing legal principle from [the

3 Supreme] Court’s decisions but unreasonably applies that principle to the facts of the prisoner’s case.

Williams, 529 U.S. at 412-13.

Ground One

Petitioner claims that the New Hampshire Supreme Court

violated his Fourteenth Amendment right to due process when it

affirmed his conviction on the four knife-related counts by

relying, in the first instance, on evidence not presented to the

jury and, ultimately, by relying upon insufficient evidence.

Respondent concedes that the Supreme Court erroneously relied

upon evidence not presented to the jury in affirming petitioner’s

convictions on the knife-related counts.4 However, respondent

argues that the evidence that was presented to the jury was

sufficient to support both the jury verdict and, consequently,

the Supreme Court’s decision to affirm the knife-related

convictions. Petitioner counters that disputed issues of

4 In his direct appeal, Hammell challenged the denial of his pre-trial motion to suppress evidence as well as his conviction. In its opinion, the Supreme Court presented a single statement of facts, drawing from the records of both the suppression hearing and the trial. In affirming Hammell’s conviction on the four knife-related charges, the Court mentioned one piece of testimony offered at the suppression hearing but not at trial.

4 material fact preclude summary judgment in respondent’s favor.

Petitioner makes the same argument regarding each of the seven

grounds in his petition. Rather than identifying material

factual disputes, however, he points to various undisputed facts

and argues that, as a logical matter, they do not support a

finding of guilt. Thus, plaintiff has raised no factual dispute

that would preclude summary judgment.

Petitioner’s constitutional right not to be convicted on

insufficient evidence is spelled out in Jackson v . Virginia, 443

U.S. 307 (1979), in which the United States Supreme Court held

that “the relevant question is whether, after viewing the

evidence in the light most favorable to the prosecution, any

rational trier of fact could have found the essential elements of

the crime beyond a reasonable doubt.” Id. at 319 (citing Johnson

v . Louisiana, 406 U.S. 356, 362 (1972)).

In his direct appeal to the New Hampshire Supreme Court,

Hammell argued that the evidence was insufficient to support any

of his twelve convictions for being a felon in possession of a

weapon. Hammell, 147 N.H. at 318. Relying upon a state

5 sufficiency-of-the-evidence rule that is the functional

equivalent of the rule established in Jackson,5 the New Hampshire

Supreme Court rejected Hammell’s claim that his conviction on the

four knife-related counts was not supported by sufficient

evidence. Id. at 319. Explaining its holding, the Court stated:

Reviewing the trial record, we hold that a rational trier of fact, evaluating all of the evidence and its reasonable inferences in the light most favorable to the State, could conclude beyond a reasonable doubt that the defendant was in control of the four knives discovered in the bedroom of the apartment. See Graham, 142 N.H. at 360. Both the defendant and Mrs. Hammell were residing in the apartment at the time of the incident.

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2004 DNH 129, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hammell-v-warden-nhd-2004.