Hawes v. Lumpkin

CourtDistrict Court, W.D. Texas
DecidedJune 21, 2024
Docket5:22-cv-01219
StatusUnknown

This text of Hawes v. Lumpkin (Hawes v. Lumpkin) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hawes v. Lumpkin, (W.D. Tex. 2024).

Opinion

1UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION RICHARD VONZELL HAWES, § TDCJ No. 02313090, § § Petitioner, § § VS. § C I V I L NO. SA-22-CA-01219-FB § BOBBY LUMPKIN, Director, § Texas Department of Criminal Justice, § Correctional Institutions Division, § § Respondent. § MEMORANDUM OPINION AND ORDER Before the Court is petitioner Richard Vonzell Hawes’s Petition for Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2254. (ECF No. 1). In the § 2254 petition, petitioner challenges the constitutionality of his 2020 state court burglary conviction, arguing that his trial counsel provided ineffective assistance. Also before the Court are respondent Bobby Lumpkin’s Answer (ECF No. 9) and petitioner’s Reply (ECF No. 14) thereto. Having reviewed the record and pleadings submitted by both parties, the Court concludes petitioner is not entitled to relief under the standards prescribed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). See 28 U.S.C. § 2254(d). Petitioner is also denied a certificate of appealability. I. Background In March 2020, petitioner was convicted in Bexar County, Texas, of one count of burglary of a habitation with intent to commit assault and sentenced to fifteen years of imprisonment. State v. Hawes, No. 2019CR10079 (290th Dist. Ct., Bexar Cnty., Tex. Mar. 11, 2020); (ECF No. 10-5 at 36-37).1 The Texas Thirteenth Court of Appeals affirmed his conviction on direct appeal. Hawes v. State, No. 13-20-00183-CR, 2021 WL 2584396 (Tex. App.—Corpus Christi-Edinburg, June 24, 2021); (ECF No. 10-9). Petitioner did not file a petition for discretionary review with the Texas Court of Criminal Appeals despite being granted an extension of time to file one by September 24,

2021. (ECF No. 10-17).2 Instead, petitioner challenged the constitutionality of his burglary conviction by filing an application for state habeas corpus relief. Ex parte Hawes, No. 93,852-01 (Tex. Crim. App.); (ECF No. 10-19 at 4-22). The Texas Court of Criminal Appeals ultimately denied the application without written order on June 29, 2022, based, in part, on the findings of the trial court. (ECF No. 10-20). Petitioner initiated the instant proceedings by filing a petition for federal habeas corpus relief on November 1, 2022. (ECF No. 1 at 10). In the petition, petitioner argues that his trial counsel

rendered ineffective assistance by: (1) failing to obtain or present a recording of a jail visit the complainant made to petitioner following his arrest, (2) failing to impeach a witness with an arrest report, and (3) either concealing or destroying a copy of the complainant’s jail visit so that petitioner could not provide it during his state habeas proceedings. Id. at 6-7. II. Standard of Review Petitioner’s federal habeas petition is governed by the heightened standard of review provided by the AEDPA. 28 U.S.C.A. § 2254. Under § 2254(d), a petitioner may not obtain federal

habeas corpus relief on any claim that was adjudicated on the merits in state court proceedings unless 1 At the same trial, petitioner was also found guilty of two counts of aggravated assault with a deadly weapon and sentenced to fifteen years of imprisonment for each offense, with all of the sentences to run concurrently. State v. Hawes, No. 2019CR10080 (290th Dist. Ct., Bexar Cnty., Tex. Mar. 11, 2020); (ECF No. 10-6 at 32-35). However, petitioner does not challenge the constitutionality of the assault convictions in the instant proceeding. 2 See also http://www.search.txcourts.gov, search for “Hawes, Richard” last visited June 12, 2024. -2- the adjudication of that claim either: (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States, or (2) 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. Brown v. Payton, 544 U.S.

133, 141 (2005). This intentionally difficult standard stops just short of imposing a complete bar on federal court relitigation of claims already rejected in state proceedings. Harrington v. Richter, 562 U.S. 86, 102 (2011) (citing Felker v. Turpin, 518 U.S. 651, 664 (1996)). A federal habeas court’s inquiry into unreasonableness should always be objective rather than subjective, with a focus on whether the state court’s application of clearly established federal law was “objectively unreasonable” and not whether it was incorrect or erroneous. McDaniel v. Brown, 558 U.S. 120 (2010); Wiggins v. Smith, 539 U.S. 510, 520-21 (2003). Even a strong case for relief

does not mean the state court’s contrary conclusion was unreasonable, regardless of whether the federal habeas court would have reached a different conclusion itself. Richter, 562 U.S. at 102. Instead, a petitioner must show that the decision was objectively unreasonable, which is a “substantially higher threshold.” Schriro v. Landrigan, 550 U.S. 465, 473 (2007); Lockyer v. Andrade, 538 U.S. 63, 75-76 (2003). So long as “fairminded jurists could disagree” on the correctness of the state court’s decision, a state court’s determination that a claim lacks merit precludes federal habeas relief. Richter, 562 U.S. at 101 (citing Yarborough v. Alvarado, 541 U.S. 652, 664 (2004)). In other words, to obtain

federal habeas relief on a claim previously adjudicated on the merits in state court, petitioner must show that the state court’s ruling “was so lacking in justification that there was an error well

-3- understood and comprehended in existing law beyond any possibility for fairminded disagreement.” Id. at 103; see also Bobby v. Dixon, 565 U.S. 23, 24 (2011). III. Analysis A. Exhaustion and Procedural Default (Claim 3)

Petitioner raises three ineffective-assistance-of-trial-counsel (IATC) claims arguing that his trial counsel’s performance violated his Sixth Amendment right to counsel. In his third allegation, petitioner contends that counsel either concealed or destroyed a recording of the complainant’s jail visit to petitioner following his arrest. In response, respondent contends that this allegation is unexhausted and procedurally barred from federal habeas corpus relief because petitioner did not raise it during his direct appeal or state habeas proceedings. Respondent is correct. Before seeking review in federal court, a habeas corpus petitioner must first present his

claims in state court and exhaust all state court remedies through proper adjudication on the merits. See 28 U.S.C. § 2254(b)(1)(A) (stating that habeas corpus relief may not be granted “unless it appears that . . . the applicant has exhausted the remedies available in the courts of the State.”). The exhaustion requirement is satisfied if the substance of the federal habeas claim was presented to the highest state court in a procedurally proper manner. Baldwin v. Reese, 541 U.S. 27, 29-32 (2004); Moore v. Cain, 298 F.3d 361, 364 (5th Cir. 2002). In Texas, the highest state court for criminal matters is the Texas Court of Criminal Appeals, and a prisoner must present the substance of his claims to the Texas Court of Criminal Appeals in either a petition for discretionary review or an

application for writ of habeas corpus under Texas Code of Criminal Procedure Article 11.07. Whitehead v.

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Bluebook (online)
Hawes v. Lumpkin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hawes-v-lumpkin-txwd-2024.