Heartsill v. State of Idaho

CourtDistrict Court, D. Idaho
DecidedNovember 12, 2024
Docket1:23-cv-00083
StatusUnknown

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

Bluebook
Heartsill v. State of Idaho, (D. Idaho 2024).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

MICHAEL S. HEARTSILL, Case No. 1:23-cv-00083-REP Petitioner, MEMORANDUM DECISION AND v. ORDER

JOSH TEWALT,

Respondent.

Pending before the Court is an Amended Petition for Writ of Habeas Corpus filed by Idaho state prisoner Michael S. Heartsill, challenging Petitioner’s state court convictions for sexual exploitation of a child. See Dkt. 11. Respondent has filed a Motion for Summary Dismissal, arguing that some of Petitioner’s claims are not cognizable and that all of the claims are procedurally defaulted. See Dkt. 17. Petitioner has filed a Motion for Appointment of Counsel. Both Motions are now ripe for adjudication. The Court takes judicial notice of the records from Petitioner’s state court proceedings, which have been lodged by Respondent. Dkt. 16; see Fed. R. Evid. 201(b); Dawson v. Mahoney, 451 F.3d 550, 551 n.1 (9th Cir. 2006). The parties have consented to the jurisdiction of a United States Magistrate Judge to conduct all proceedings in this case in accordance with 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73. See Dkt. 9. Having carefully reviewed the record, including the state court record, the Court finds that oral argument is unnecessary. See D. Idaho L. Civ. R. 7.1(d). Accordingly, the Court will enter the following Order denying Petitioner’s

Motion for Appointment of Counsel and granting Respondent’s Motion for Summary Dismissal. BACKGROUND In the Fifth Judicial District Court in Twin Falls County, Idaho, Petitioner was charged with fifty counts of sexual exploitation of a child. He pleaded guilty to twenty-

five counts in exchange for the dismissal of the other twenty-five. State’s Lodging D-16 at 1. Petitioner received unified aggregate sentences of forty years with twenty-three years fixed. Id. The Idaho Supreme Court affirmed, and the Idaho Supreme Court denied review. State’s Lodging B-4; B-6. Petitioner then pursued state post-conviction relief. The state district court

dismissed the post-conviction petition after an evidentiary hearing. State’s Lodging C-1 at 93–107; C-3 at 29–159. Petitioner appealed. His post-conviction appellate counsel was later permitted to withdraw, and Petitioner proceeded pro se. The Idaho Court of Appeals affirmed the dismissal of the post-conviction petition. State’s Lodging D-16. Petitioner did not seek review in the Idaho Supreme Court. See

State’s Lodging D-21. Instead, Petitioner filed a number of motions in the Idaho Court of Appeals, which that court construed as requests for reconsideration of its decision. State’s Lodging D-22; D-23; D-24; D-25. The state appellate court denied the motions. State’s Lodging D-26. In the instant federal habeas corpus petition, Petitioner asserts the following claims: Claim 1 asserts ineffective assistance of counsel with respect to Petitioner’s plea bargain. Specifically, the claim alleges that counsel told Petitioner he was subject only to a 10-year maximum sentence and that Petitioner would receive a rider. Claim 2 is similar to Claim 1, but also asserts that counsel told Petitioner he “need not worry” about a recommendation of consecutive sentences and that counsel “gloss[ed] over important parts of the” guilty plea advisory form, including No. 36. Petitioner also claims he was “coerced” into signing the plea agreement. Claim 3 asserts that counsel rendered ineffective assistance in failing to correct misstatements made by the judge at sentencing upon which the judge relied in determining Petitioner’s sentence. Claim 4 asserts that the sentencing judge relied on incorrect assumptions, violated Idaho Code § 19-2521, and as a result, imposed an excessive sentence. The claim also alleges that the judge denied Petitioner “his constitutional right to a fair and impartial trial,” but there do not appear to be any facts supporting this portion of Claim 4. Claim 5 appears to assert that Petitioner’s sentence violates the Eighth Amendment because he is not eligible for treatment or other rehabilitation services in prison until six months before he completes his fixed term of imprisonment. In Claim 6, Petitioner alleges that defense counsel was ineffective at sentencing by failing to present live testimony of witnesses who could have testified on Petitioner’s behalf. Instead, those witnesses merely submitted letters. Claim 7 asserts that the prosecutor committed misconduct at sentencing. Petitioner claims the prosecutor made misleading and false statements, “which helped sway the judge’s decision.” Claim 8 alleges that Petitioner’s post-conviction conflict attorney repeatedly attempted to withdraw from the representation instead of promptly submitting an amended post-conviction petition. In Claim 9, Petitioner asserts prosecutorial misconduct based on the prosecutor attacking Petitioner’s character. Claim 9 also appears to allege that Petitioner’s counsel was ineffective for failing to controvert or object to the prosecutor’s statements. Claim 10 asserts various errors during the course of Petitioner’s post-conviction proceedings. Finally, Claim 11 contends that Petitioner’s post- conviction counsel was ineffective for not responding to Petitioner’s attempts at contact and not providing requested information. Init. Rev. Order, Dkt. 12, at 2–3 (internal citations and footnote omitted). The Court previously reviewed the Petition and allowed Petitioner to proceed on his claims to the extent those claims “(1) are cognizable—meaning they actually can be heard—in a federal habeas corpus action, (2) were timely filed in this Court, and (3) were either properly exhausted in state court or subject to a legal excuse for any failure to exhaust in a proper manner.” Id. at 4. DISCUSSION 1. Petitioner’s Motion for Appointment of Counsel As the Court has previously explained, there is no constitutional right to counsel in a habeas corpus action. Coleman v. Thompson, 501 U.S. 722, 755 (1991); see Init. Rev. Order at 5. A habeas petitioner has a right to counsel, as provided by rule, if an evidentiary hearing is required in the case. Habeas Rule 8(c). In addition, the Court may exercise its discretion to appoint counsel for an indigent petitioner in any case where required by the interests of justice. 28 U.S.C. § 2254(h); 18 U.S.C. § 3006A(a)(2)(B). Whether counsel should be appointed turns on the petitioner’s ability to articulate the

claims in light of the complexity of the legal issues and the petitioner’s likelihood of success on the merits. Weygandt v. Look, 718 F.2d 952, 954 (9th Cir. 1983) (per curiam). Here, an evidentiary hearing is not required to determine whether Petitioner’s claims are cognizable or whether they are procedurally defaulted. Moreover, Petitioner has been able to represent himself in this matter and protect his interests to date.

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Heartsill v. State of Idaho, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heartsill-v-state-of-idaho-idd-2024.