Haniffy v. NHSP Warden

2010 DNH 014
CourtDistrict Court, D. New Hampshire
DecidedJanuary 26, 2010
Docket08-CV-268-SM
StatusPublished

This text of 2010 DNH 014 (Haniffy v. NHSP 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
Haniffy v. NHSP Warden, 2010 DNH 014 (D.N.H. 2010).

Opinion

Haniffy v . NHSP Warden 08-CV-268-SM 01/26/10 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Joseph Haniffy, Petitioner

v. Civil N o . 08-cv-268-SM Opinion N o . 2010 DNH 014 Richard Gerry, Warden, New Hampshire State Prison, Respondent

O R D E R

Joseph Haniffy, a New Hampshire State Prison inmate,

petitions for a writ of habeas corpus. 42 U.S.C. § 2254. Before

the court is respondent’s motion for summary judgment. Haniffy

objects. For the reasons given, respondent’s summary judgment

motion is granted in part and denied in part.

Background

Haniffy was convicted of three counts of aggravated

felonious sexual assault in the New Hampshire Superior Court.

Over Haniffy’s objection, first raised in a motion in limine, the

trial court admitted the testimony of Haniffy’s codefendants,

Christopher Armstrong and Cassidy Coburn. Haniffy’s objection

was based on his concern that the State would use Armstrong and

Coburn to introduce inadmissable hearsay evidence. On the fifth day of trial, Haniffy offered his cell phone

into evidence, and it was duly admitted. At the close of the

evidence, the cell phone was sent into the jury room, along with

the rest of the exhibits. While deliberating, the jury sent out

a note asking permission to turn the cell phone on. Neither side

objected. Shortly after the jury rendered its verdict, the trial

court became aware of a notation by a juror, left in the jury

room along with the exhibits, indicating that when the phone was

turned o n , it displayed the name “Joe Pimp.”

After conferring with counsel, the trial judge recalled the

jury and conducted individual voir dire to determine what

material, if any, the jurors discovered on the cell phone. The

judge asked each juror, under oath, whether he or she had seen,

or had heard other jurors talk about the display that came up

when the phone was turned o n , photographs stored on the phone,

names listed in the phone’s directory, e-mails stored on the

phone, or any other material stored in or displayed by the phone.

Each juror testified that he or she saw, or heard others

mention, the name “Joe Pimp.” Juror #12, who turned the phone

o n , testified that she saw a New York Yankees’ logo, and saw that

there were photographs stored on the phone. She also testified

that she did not look through the photos. The other eleven

2 jurors all testified that they neither saw nor heard about any

photographs. Juror #12 also testified that she saw the phone

display a list of contacts, but that she did not read the list.

Juror #10 testified that he heard something about Haniffy’s

girlfriend’s name being displayed by the phone. The other ten

jurors all testified that they neither saw nor heard of a

telephone directory or any names listed in such a directory.

Juror #1 testified that he heard about some e-mail correspondence

between Haniffy and his girlfriend stored on the phone. The

other eleven jurors all testified that they neither saw nor heard

of any e-mail on the phone. Each juror was asked whether he or

she saw or heard about any other material on the phone, and none

mentioned any material apart from that described above.

After the voir dire, Haniffy filed a motion for a new trial,

arguing that “[t]he jury’s exposure during deliberations to

extrinsic evidence, whatever its source, is an error of

constitutional proportions that is grounds for setting aside the

verdict.” (Mot. Summ. J., Ex. F (document n o . 1 4 - 5 ) , at 1.)

Specifically, Haniffy argued that “[t]he jurors’ exposure to the

name ‘Joe Pimp’ on [his] cellphone amounted to the jury being

exposed to factual information outside of the record of the trial

and this is an error of constitutional proportions that is

grounds for setting aside the verdicts.” (Id. at 3.) The trial

3 court denied Haniffy’s motion in a thirteen-page order in which

it analyzed the prejudicial effect of the name “Joe Pimp.”1 (See

id., Ex. J (document n o . 14-9).) Subsequently, the trial court

sentenced Haniffy to seven and a half to twenty years in the New

Hampshire State Prison, with a second sentence of ten to twenty

years deferred.

Haniffy appealed his conviction. His notice of appeal

listed ten issues, including these:

1 . Did the Court err in denying the defendant’s Motion in Limine #1 (Testimony of Armstrong and Coburn)?

2 . Did the Court err in allowing the State to ask questions of the co-defendants that were designed to elicit inadmissible hearsay?

3 . Did the Court err in denying the defendant’s Motion for a New Trial?

(Status Report, Attach. 4 (document no 5 - 5 ) , at 3.) Of those

three issues, Haniffy briefed only the first: “Whether the trial

court erred in denying [his] motion to preclude the testimony of

the co-defendants?” With regard to that issue, the Supreme Court

affirmed the trial court’s decision to deny Haniffy’s motion to

exclude the testimony of Armstrong and Coburn.

1 Because Haniffy’s motion was based only on the “Joe Pimp” screen name, the court did not address any of the other material that Jurors 1 , 1 0 , and 12 said they saw or heard about.

4 In January of 2008, Haniffy filed a motion to retrieve

evidence, namely the digital information contained in his cell

phone. By the middle of February, the phone was in the

possession of Haniffy’s attorney, who began to examine its

contents and partially described them in a memorandum to the

file. (See Case Status Report, Ex. A (document n o . 7 - 2 ) , at 12-

13.) That memorandum was in Haniffy’s possession no later than

July of 2008. It mentioned, among other things, records of two

phone calls to someone called “hot bitch,” photographs of women

exposing their breasts, and photos or files with labels such as

“Girls Gone Wild,” “Fine Young Boobs,” “Strippers,” and “Very

Nice Ass.” (Id.) In July of 2008, and again in December of

2008, Haniffy asked the Superior Court to inform him of the

status of his motion to retrieve evidence. Then, in February of

2009, he filed a second motion for a new trial, arguing that his

trial was constitutionally unfair because the jury was exposed to

a variety of prejudicial extrinsic evidence contained in his cell

phone. The State objected, on grounds that Haniffy filed his

motion after the expiration of the three-year time limit

established by N . H . R E V . STAT. A N N . § 526:4, and because he had

already litigated the same issue in his previous motion for a new

trial. The Superior Court denied Haniffy’s motion “[f]or the

reasons given in the State’s object[ion].” (Id. at 7.) Haniffy

5 appealed, and the state Supreme Court declined his notice of

appeal.

As construed by the magistrate judge, Haniffy’s petition for

habeas relief consists of the following three claims:

1. Haniffy’s due process and fair trial rights, guaranteed by the Sixth and Fourteenth Amendments, were violated when the Court allowed his codefendants to testify at his trial, which allowed the prosecution to improperly introduce the substance of hearsay statements of the codefendants into evidence.

2.

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