Hevi v. Pelle

CourtDistrict Court, D. Colorado
DecidedMarch 15, 2023
Docket1:20-cv-03153
StatusUnknown

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

Bluebook
Hevi v. Pelle, (D. Colo. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Philip A. Brimmer Civil Action No. 20-cv-03153-PAB PERCY “KOMLA” HEVI, Petitioner. v. BOULDER COUNTY SHERIFF, Joe Pelle, Respondent. ORDER ON PETITION FOR WRIT OF HABEAS CORPUS

This matter is before the Court on the pro se Application for a Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2254 [Docket No. 1]. Percy “Komla” Hevi challenges the validity of his misdemeanor conviction in Boulder County Court case 16M1559. Docket No. 1 at 2.

I. BACKGROUND Mr. Hevi states that he was charged with “unlawful sexual contact” for “purportedly grabbing the genitalia of the complaining witness while she was riding a bicycle . . . at a main intersection during rush hour in the City of Boulder.” Id. at 3. Mr. Hevi was convicted by a jury in Boulder County Court of unlawful sexual conduct, a misdemeanor, and sentenced to a term of 24 months in the Boulder County Jail to be served on work release. Docket No. 22-4 at 1. Mr. Hevi appealed to the Boulder County District Court (“Boulder District Court”), which affirmed his conviction. Id. at 5; see also People v. Hevi, 2019 Colo. Dist. LEXIS 4732, *2 (Boulder Dist. Ct. Apr. 23, 2019). The Colorado Supreme Court denied Mr. Hevi’s petition for a writ of certiorari. Docket No. 1 at 2. Mr. Hevi argues that his conviction violated his Sixth Amendment confrontation rights, and he asks that his conviction be vacated and his sentence be stayed pending resolution of this application. Id. at 3–5. In his habeas petition, Mr. Hevi initially named

as respondents Boulder County Sheriff Joe Pelle (“Sheriff”) and the Attorney General of the State of Colorado (“Colorado Attorney General”). Id. at 1. On November 23, 2020, counsel entered an appearance for Mr. Hevi. Docket No. 8. On December 3, 2020, the Court granted the parties’ unopposed motion to dismiss the Colorado Attorney General. Docket No. 10. The Sheriff filed a pre-answer response on December 17, 2020 and indicated that he would not raise the affirmative defenses of timeliness under 28 U.S.C. § 2254(d)(1) or failure to exhaust state court remedies. Docket No. 11 at 1. Rather, the Sheriff argued that the application would be rendered moot by Mr. Hevi’s scheduled

release from the Sheriff’s custody the following week. Id. Mr. Hevi filed a reply on January 11, 2021, arguing that although he was released from custody, the application is not moot. Docket No. 13 at 1. Before this matter was drawn to this Court, Senior District Judge Lewis T. Babcock issued an order explaining that, when a habeas petitioner challenges only an expired sentence, the petitioner must identify an “ongoing ‘collateral consequenc[e]’ that is ‘traceable’ to the challenged portion of the sentence and ‘likely to be redressed by a favorable judicial decision.’” Docket No. 14 at 3 (quoting Spencer v. Kemna, 523 U.S. 1, 7 (1988)). Judge Babcock found that the only collateral consequence that Mr. Hevi 2 identified in his habeas petition is the requirement that Mr. Hevi register as a sex offender under Colo. Rev. Stat. § 16-22-102(9)(c)(I). Id. (citing Docket No. 13 at 1). However, Judge Babcock determined that the sex offender registration requirement is a collateral consequence of Mr. Hevi’s conviction, not his sentence, which makes that request for relief moot. Id. at 3–4 (citing United States v. Juvenile Male, 564 U.S. 932,

937–38 (2011) (concluding that independent state duty to register as a sex offender was not a “collateral consequence” of petitioner’s expired sentence)). Judge Babcock further determined that Mr. Hevi’s challenge to his misdemeanor conviction itself is not mooted by his release from custody. Id. at 4. (citing Spencer, 523 U.S. at 8 (“[T]he Supreme Court presumes that a wrongful criminal conviction has continuing collateral consequences sufficient to present a case or controversy and avoid dismissal on the ground of mootness.”)). II. STANDARD OF REVIEW Title 28 U.S.C. § 2254(d) provides that a writ of habeas corpus may not be

issued with respect to any claim that was adjudicated on the merits in state court unless the state court adjudication: (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. 28 U.S.C. § 2254(d). Mr. Hevi bears the burden of proof under § 2254(d). See Cullen v. Pinholster, 563 U.S. 170, 181 (2011). The Court’s inquiry is straightforward “when the last state court to decide a 3 prisoner’s federal claim explains its decision on the merits in a reasoned opinion.” Wilson v. Sellers, 138 S. Ct. 1188, 1192 (2018). “In that case, a federal habeas court simply reviews the specific reasons given by the state court and defers to those reasons if they are reasonable.” Id. When the last state court decision on the merits “does not come accompanied with those reasons,” the federal court should “‘look

through’ the unexplained decision to the last related state-court decision that does provide a relevant rationale [and] presume that the unexplained decision adopted the same reasoning.” Id. The presumption may be rebutted “by showing that the unexplained affirmance relied or most likely did rely on different grounds than the lower state court's decision, such as alternative grounds for affirmance that were briefed or argued to the state supreme court or obvious in the record it reviewed.” Id. The threshold question the Court must answer under § 2254(d)(1) is whether Mr. Hevi seeks to apply a rule of law that was clearly established by the Supreme Court at the time the state court adjudicated the claim on its merits. Greene v. Fisher, 565 U.S.

34, 38 (2011). Clearly established federal law “refers to the holdings, as opposed to the dicta, of [the Supreme] Court’s decisions as of the time of the relevant state-court decision.” Williams v. Taylor, 529 U.S. 362, 412 (2000). Furthermore, clearly established law consists of Supreme Court holdings in cases where the facts are at least closely-related or similar to the case sub judice. Although the legal rule at issue need not have had its genesis in the closely-related or similar factual context, the Supreme Court must have expressly extended the legal rule to that context. House v. Hatch, 527 F.3d 1010, 1016 (10th Cir. 2008). If there is no clearly established federal law, that is the end of the Court’s inquiry pursuant to § 2254(d)(1). See id. at 1018. 4 If a clearly established rule of federal law is implicated, the Court must determine whether the state court’s decision was contrary to or an unreasonable application of that clearly established rule of federal law. See Williams, 529 U.S. at 404–05.

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