Hayes v. Howell

CourtDistrict Court, D. Nevada
DecidedJune 1, 2022
Docket2:20-cv-00945
StatusUnknown

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

Bluebook
Hayes v. Howell, (D. Nev. 2022).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT

7 DISTRICT OF NEVADA

8 * * * 9 JAMES H. HAYES, Case No. 2:20-cv-00945-GMN-BNW

10 Petitioner, ORDER

11 v. 12 JERRY HOWELL, et al., 13 Respondents. 14 15 James H. Hayes’ pro se 28 U.S.C. § 2254 habeas corpus petition is before the 16 court for final adjudication on the merits (ECF Nos. 5, 6). As discussed below, the 17 petition is denied. 18 I. Background & Procedural History 19 As set forth in this court’s order granting respondents’ motion to dismiss in part, 20 this case arises out of incidences in early 2016 in Harrah’s Hotel & Casino in Las 21 Vegas, Nevada, when a high number of guests reported items stolen from their rooms 22 (see ECF No. 12, p. 2). Harrah’s set up a staged hotel room, with $350 in a wallet and 23 other property including an iPad and left the door slightly ajar. They placed cameras 24 inside and surveilled from the room next door. In the early morning hours, Hayes 25 checked the door to the room and entered. He took the money from the wallet, and 26 hotel security apprehended him when he exited the room. 27 1 In January 2017, a jury found Hayes guilty of burglary (exhibit 39).' The state 2 || district court sentenced him to a term of 21 to 72 months. Exh. 48. Judgment of 3 || conviction was entered on March 13, 2017. /d. 4 The Nevada Court of Appeals affirmed Hayes’ conviction in 2018. Exh. 126. The 5 || Nevada Court of Appeals affirmed the denial of his state postconviction habeas corpus 6 || petition in 2020. Exh. 207. 7 Hayes dispatched his federal habeas corpus petition for filing in May 2020 (ECF 8 || No. 6). Respondents have now answered the remaining seven grounds for relief (ECF 9 |) No. 49). Hayes filed a traverse and an addendum (ECF Nos. 54, 58). The court has 10 || considered all briefing. 11 ll. LEGAL STANDARD -Antiterrorism and Effective Death Penalty Act 12 (AEDPA) 13 14 28 U.S.C. § 2254(d), a provision of the Antiterrorism and Effective Death Penalty 15 || Act (AEDPA), provides the legal standards for this court’s consideration of the petition in 16 || this case: 17 An application for a writ of habeas corpus on behalf of a person in 18 custody pursuant to the judgment of a State court shall not be granted with respect to any claim that was adjudicated on the merits in State court 19 proceedings unless the adjudication of the claim —

20 (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined 24 by the Supreme Court of the United States; or 22 (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State 23 court proceeding. 24 || The AEDPA “modified a federal habeas court’s role in reviewing state prisoner 25 || applications in order to prevent federal habeas ‘retrials’ and to ensure that state-court 26 || convictions are given effect to the extent possible under law.” Bell v. Cone, 535 U.S. 27 28 Exhibits referenced in this order are exhibits to respondents’ motion to dismiss, ECF No. 12, and are found at ECF Nos. 13-26.

1 685, 693-694 (2002). This court’s ability to grant a writ is limited to cases where “there is 2 no possibility fair-minded jurists could disagree that the state court’s decision conflicts 3 with [Supreme Court] precedents.” Harrington v. Richter, 562 U.S. 86, 102 (2011). The 4 Supreme Court has emphasized “that even a strong case for relief does not mean the 5 state court’s contrary conclusion was unreasonable.” Id. (citing Lockyer v. Andrade, 538 6 U.S. 63, 75 (2003)); see also Cullen v. Pinholster, 563 U.S. 170, 181 (2011) (describing 7 the AEDPA standard as “a difficult to meet and highly deferential standard for evaluating 8 state-court rulings, which demands that state-court decisions be given the benefit of the 9 doubt”) (internal quotation marks and citations omitted). 10 A state court decision is contrary to clearly established Supreme Court 11 precedent, within the meaning of § 2254, “if the state court applies a rule that 12 contradicts the governing law set forth in [the Supreme Court’s] cases” or “if the state 13 court confronts a set of facts that are materially indistinguishable from a decision of [the 14 Supreme Court] and nevertheless arrives at a result different from [the Supreme 15 Court’s] precedent.” Lockyer, 538 U.S. at 73 (quoting Williams v. Taylor, 529 U.S. 362, 16 405-06 (2000), and citing Bell, 535 U.S. at 694. 17 A state court decision is an unreasonable application of clearly established 18 Supreme Court precedent, within the meaning of § 2254(d), “if the state court identifies 19 the correct governing legal principle from [the Supreme Court’s] decisions but 20 unreasonably applies that principle to the facts of the prisoner’s case.” Lockyer, 538 21 U.S. at 74 (quoting Williams, 529 U.S. at 413). The “unreasonable application” clause 22 requires the state court decision to be more than incorrect or erroneous; the state 23 court’s application of clearly established law must be objectively unreasonable. Id. 24 (quoting Williams, 529 U.S. at 409). 25 To the extent that the state court’s factual findings are challenged, the 26 “unreasonable determination of fact” clause of § 2254(d)(2) controls on federal habeas 27 review. E.g., Lambert v. Blodgett, 393 F.3d 943, 972 (9th Cir.2004). This clause requires 1 determinations. Id. The governing standard is not satisfied by a showing merely that the 2 state court finding was “clearly erroneous.” 393 F.3d at 973. Rather, AEDPA requires 3 substantially more deference:

4 .... [I]n concluding that a state-court finding is unsupported by substantial evidence in the state-court record, it is not enough that we would reverse in 5 similar circumstances if this were an appeal from a district court decision. Rather, we must be convinced that an appellate panel, applying the normal 6 standards of appellate review, could not reasonably conclude that the finding is supported by the record. 7 8 Taylor v. Maddox, 366 F.3d 992, 1000 (9th Cir.2004); see also Lambert, 393 9 F.3d at 972. 10 Under § 2254(e)(1), state court factual findings are presumed to be correct 11 unless rebutted by clear and convincing evidence. The petitioner bears the burden of 12 proving by a preponderance of the evidence that he is entitled to habeas relief. Cullen, 13 563 U.S. at 181. 14 III. Trial Testimony 15 Harrah’s security investigator David Travis testified that, due to an unusually high 16 number of thefts, on April 1-2, 2016, he and two other security officers staged property 17 in a hotel room, including suitcases, clothing, toiletries, jewelry, an iPad, and a wallet 18 with $350 in cash, and set up cameras. Exh. 37, pp. 202-252. They monitored the room 19 from the room next door. The officers had photocopied the money. They left the door 20 slightly ajar as if to look like a guest failed to close it properly. Just before 2 a.m. the 21 officers observed a man going down the hallway; it appeared that he was checking 22 doors. When he found that that door was open, he entered the room. The officers 23 watched the man, via the cameras, take the cash out of the wallet and put it in his front 24 left pants pocket. When the man exited the room, security officers were waiting outside 25 to detain him. Travis identified Hayes in court as the man that they detained.

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Hayes v. Howell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hayes-v-howell-nvd-2022.