Hampton v. Warden, Madison Correctional Institution

District Court, S.D. Ohio·Decided October 3, 2023·No. 2:22-cv-04246·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

KENNETH D. HAMPTON,

Petitioner, : Case No. 2:22-cv-4246

- vs - District Judge Michael H. Watson Magistrate Judge Michael R. Merz

WARDEN, Madison Correctional Institution,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case is brought pro se by Petitioner Kenneth Hampton pursuant to 28 U.S.C. § 2254 to obtain relief from his conviction in the Licking County Court of Common Pleas on drug trafficking and weapons charges (Petition, ECF No. 4). On Magistrate Judge Deavers’ Order, Respondent has filed the State Court Record (ECF No. 7) and a Return of Writ (ECF No. 8). Petitioner has filed a Reply (ECF No. 14), making the case ripe for decision. The Magistrate Judge reference in the case was recently transferred to the undersigned to help balance the workload in the District.

Litigation History On May 27, 2020, the Licking County Grand Jury returned a superseding indictment charging Petitioner with sixteen felony counts, fourteen involving illicit drugs and two weapons charges (Indictment, State Court Record, ECF No. 7, Ex. 2). The trial judge allowed Hampton to file an untimely motion to suppress, but denied it after hearing. A jury convicted Petitioner on all counts. After merging some counts, the trial judge sentenced Petitioner to ten to fifteen years imprisonment. The convictions were affirmed on direct appeal. State v. Hampton, 2021-Ohio- 1873 (Ohio App. 5th Dist. Jun. 1, 2021). Hampton did not file a timely appeal to the Supreme Court of Ohio. He was granted leave to file a delayed appeal which was then dismissed for want

of prosecution when he failed to file a memorandum in support of jurisdiction (State Court Record, ECF No. 7, Ex. 17). Hampton timely initiated these habeas proceeding by placing his Petition in the prison mail system on November 15, 2022. He pleads the following Grounds for Relief: Ground One: Ineffective assistance of appellate counsel, pursuant to the U.S. Sixth and Fourteenth Constitutional Amendments.

Supporting Facts: Deficient assignments of errors, presented within appellant’s brief.

Ground Two: Conviction was against the manifest weight of the evidence.

Supporting Facts: Two (2) other accused/defendants (persons of interest) one (1) of which was the sole owner of the vehicle petitioner was a passenger in weren’t officially charged nor convicted of any of the offenses Petitioner was convicted of.

Ground Three: The trial court abused its discretion in failing to render judgment upon appellant/petitioner’s motion to suppress evidence.

Supporting Facts: Petitioner had a motion to suppress evidence filed in the trial court, however, said motion was never ruled upon nor rendered a final appealable order.

Ground Four: Petitioner was deprived of the effective assistance of trial counsel.

Supporting Facts: Failure to prepare a proper defense and retrieve exculpatory discovery evidence favorable to the Petitioner. (Petition, ECF No. 4).

Analysis

Ground One: Ineffective Assistance of Appellate Counsel

In his First Ground for Relief, Hampton asserts he received ineffective assistance of appellate counsel when his direct appeal attorney presented unspecified deficient assignments of error. Respondent asserts this claim is procedurally defaulted because it was never fairly presented to the Ohio courts. The procedural default doctrine in habeas corpus is described by the Supreme Court as follows:

In all cases in which a state prisoner has defaulted his federal claims in state court pursuant to an adequate and independent state procedural rule, federal habeas review of the claims is barred unless the prisoner can demonstrate cause of the default and actual prejudice as a result of the alleged violation of federal law; or demonstrate that failure to consider the claims will result in a fundamental miscarriage of justice.

Coleman v. Thompson, 501 U.S. 722, 750 (1991); see also Simpson v. Jones, 238 F.3d 399, 406 (6th Cir. 2000). That is, a petitioner may not raise on federal habeas a federal constitutional rights claim he could not raise in state court because of procedural default. Wainwright v. Sykes, 433 U.S. 72 (1977); Engle v. Isaac, 456 U.S. 107, 110 (1982). “Absent cause and prejudice, ‘a federal habeas petitioner who fails to comply with a State’s rules of procedure waives his right to federal habeas corpus review.’” Boyle v. Million, 201 F.3d 711, 716 (6th Cir. 2000), quoting Gravley v. Mills, 87 F.3d 779, 784-85 (6th Cir. 1996); Murray v. Carrier, 477 U.S. 478, 485 (1986); Engle, 456 U.S. at 110; Wainwright, 433 U.S. at 87. [A] federal court may not review federal claims that were procedurally defaulted in state court—that is, claims that the state court denied based on an adequate and independent state procedural rule. E.g., Beard v. Kindler, 558 U.S. 53, 55, 130 S.Ct. 612, 175 L.Ed.2d 417 (2009). This is an important “corollary” to the exhaustion requirement. Dretke v. Haley, 541 U.S. 386, 392, 124 S.Ct. 1847, 158 L.Ed. d 659 (2004). “Just as in those cases in which a state prisoner fails to exhaust state remedies, a habeas petitioner who has failed to meet the State’s procedural requirements for presenting his federal claims has deprived the state courts of an opportunity to address” the merits of “those claims in the first instance.” Coleman [v. Thompson], 501 U.S. [722,] 731-732, 111 S.Ct. 2546, 115 L.Ed.2d 640 [(1991)]. The procedural default doctrine thus advances the same comity, finality, and federalism interests advanced by the exhaustion doctrine. See McCleskey v. Zant, 499 U.S. 467, 493, 111 S.Ct. 1454, 113 L.Ed.2d 517 (1991).

Davila v. Davis, 582 U.S. 521, 527 (2017). “[A] federal court may not review federal claims that were procedurally defaulted in state courts.” Theriot v. Vashaw, 982 F.3d 999 (6th Cir. 2020), citing Maslonka v. Hoffner, 900 F.3d 269, 276 (6th Cir. 2018) (alteration in original) (quoting Davila v. Davis, 582 U.S. 521, 527(2017)). Ohio law provides a method for raising ineffective assistance of appellate counsel claims by application for reopening under Ohio R. App. P. 26(B). However Hampton has never filed such an application and the time within which such an application could be filed expired ninety days after the Fifth District decided the appeal. Hampton seeks to excuse this procedural default by claiming he is actually innocent (Reply, ECF No. 14). The controlling precedent on this point is now the Supreme Court’s decision in McQuiggin v. Perkins, 569 U.S. 383 (2013). [A]ctual innocence, if proved, serves as a gateway through which a petitioner may pass whether the impediment is a procedural bar, as it was in Schlup and House, or, as in this case, expiration of the statute of limitations.

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Hampton v. Warden, Madison Correctional Institution, (S.D. Ohio 2023).

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Related

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