HOLMES v. NEAL

CourtDistrict Court, S.D. Indiana
DecidedJanuary 27, 2023
Docket1:05-cv-01763
StatusUnknown

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

Bluebook
HOLMES v. NEAL, (S.D. Ind. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

ERIC D. HOLMES, ) ) Petitioner, ) ) v. ) No. 1:05-cv-01763-SEB-KMB ) ED BUSS, ) ) Respondent. )

Order Denying Motion to Stay and Dismissing Successive Petition for Writ of Habeas Corpus Eric D. Holmes is an Indiana inmate who has been sentenced to death. He brought this petition for writ of habeas corpus in 2005. The Court found that the petition was an unauthorized second or successive petition and dismissed it for lack of jurisdiction. Dkt. 21. The Seventh Circuit reversed and remanded, directing this Court to stay proceedings on the case because Mr. Holmes was incompetent to litigate it. Dkt. 42. In June 2021, following developments in the law, the Court reopened proceedings and directed Mr. Holmes to show cause why this action should not be dismissed for lack of jurisdiction. Mr. Holmes responded with another motion to stay, which the respondent opposes. I. Background A. Trial and Initial State Proceedings Mr. Holmes was found guilty by an Indiana jury of the 1989 murders of Charles Ervin and Theresa Blosl, as well as the attempted murder of Amy Foshee. The jury in Mr. Holmes's case did not reach a unanimous sentencing recommendation. Holmes v. State, 671 N.E.2d 841, 845 (Ind. 1996). After the penalty phase of trial, the court sentenced Mr. Holmes to death for the murder of Blosl and to prison terms for his other convictions. State v. Holmes, 728 N.E.2d 164, 167 (Ind. 2000). Mr. Holmes unsuccessfully challenged his murder convictions and death sentence in state court on direct appeal and in post-conviction proceedings. B. Initial Habeas Corpus Proceedings In 2000, Mr. Holmes brought a petition for writ of habeas corpus in the United States

District Court for the Southern District of Indiana challenging his convictions and sentences pursuant to 28 U.S.C. § 2254. Holmes v. Davis, 1:00-cv-1477-SEB-DML (S.D. Ind.). The Court denied his petition on the merits in September 2004. See Holmes v. Davis, 1:00-cv-1477- SEB-DML, dkt. 1 (S.D. Ind. Sept. 2, 2004). C. Successive State Post-Conviction Proceedings When Mr. Holmes was tried in 1992, "Indiana law clearly authorized the judge to 'override' a jury recommendation if the judge found the statutory aggravating circumstances to outweigh any mitigating circumstances." Saylor v. Indiana, 808 N.E.2d 646, 648 (Ind. 2004). In 2002, while Mr. Holmes's original § 2254 petition was pending, Indiana law was changed to remove this authority from the trial court. Id. In 2004, the Indiana Supreme Court vacated the death sentence

of Benny Saylor, an inmate who was sentenced to death under the prior regime despite a contrary recommendation by the jury. Saylor, 808 N.E.2d at 650.1 In light of Saylor, Mr. Holmes sought leave to file a successive state post-conviction petition. Holmes v. State, 820 N.E.2d 136, 138 (Ind. 2005). However, the Indiana Supreme Court

1 The Indiana Supreme Court identified two other inmates who had been sentenced to death in Indiana despite a contrary jury recommendation: William Minnick and Obadyah Ben–Yisrayl. Saylor, 808 N.E.2d at 647 n.1. Mr. Minnick's and Mr. Ben-Yisrayl's death sentences were vacated in separate state post- conviction proceedings, and both are now serving terms of years. See Minnick v. State, 965 N.E.2d 124, 127−29 (Ind. 2012); Ben-Yisrayl v. Buss, 540 F.3d 542, 545 (7th Cir. 2008). The Indiana Supreme Court also identified two inmates who had been sentenced to death without a unanimous recommendation from the jury: Mr. Holmes and Gary Burris. Saylor, 808 N.E.2d at 650. Mr. Burris was executed in 1997, before Indiana changed its capital sentencing regime. See "A History of Executions in Indiana," Dawn Mitchell, IndyStar, Dec. 11, 2019, https://www.indystar.com/story/news/2019/12/11/indiana-executions-full-list- people-executed-since-1897/4357164002/. denied his request, holding that "Indiana law still authorizes the sentencing judge to impose a death sentence if the jury cannot agree on a sentencing recommendation." Id. at 138; see Ind. Code. § 35-50-2-9(f) and (g). D. Successive § 2254 Petition and Direction to Stay Proceedings

Upon the Indiana Supreme Court's denial of leave to file a successive post-conviction petition, Mr. Holmes brought a new § 2254 petition in this Court. Dkt. 1. In it, he contended that the Indiana Supreme Court violated his rights to equal protection and due process by declining to modify his sentence as it did for Benny Saylor. Dkt. 2 at 30−48. The Court found that the new petition was an unauthorized second or successive petition and dismissed it for lack of jurisdiction. Dkt. 21. Mr. Holmes appealed, and it was consolidated with the appeal from the denial of his original § 2254 petition. The United States Court of Appeals for the Seventh Circuit concluded that Mr. Holmes was incompetent to assist in litigating his habeas petitions—or even whether to decide whether to proceed in the litigation at all:

Holmes testified that his "mental state shouldn't be an issue." If he is competent, he has by that statement seemingly made a choice to go for broke—to obtain a determination from us of the merits of his habeas corpus action rather than allow the proceeding to be suspended until such time as he is restored to sanity (a time that no one expects ever to arrive). We do not think that he is competent to make such a decision.

Holmes v. Levenhagen, 600 F.3d 756, 762 (7th Cir. 2010). The Seventh Circuit therefore reversed the district court's judgments and remanded with instructions "to suspend the habeas corpus proceeding unless and until the state provides substantial new evidence that Holmes's psychiatric illness has abated, or its symptoms are sufficiently controlled, to justify the resumption of the proceeding." Id. at 763. E. Ryan v. Gonzales and Resolution of Original § 2254 Habeas Petition In 2013, the Supreme Court held that a habeas petitioner who has been sentenced to death has no statutory right to competence during habeas proceedings. Ryan v. Gonzales, 568 U.S. 57, 64−73 (2013). The Supreme Court also explained that a district court should not stay proceedings

based on a petitioner's incompetence unless (1) "the petitioner's claim could substantially benefit from the petitioner's assistance" and (2) there is "reasonable hope of competence" in the foreseeable future. Id. at 76−77. In light of Ryan, this Court granted respondent's motion to lift the stay in Mr. Holmes's original habeas proceedings, reissued the order denying habeas relief, and reissued final judgment. Holmes v. Davis, 1:00-cv-1477-SEB-DML, dkt. 138; dkt. 139; dkt. 140 (S.D. Ind. Sept. 26, 2014). The Seventh Circuit affirmed. Holmes v. Neal, 816 F.3d at 955. F. Motion to Reinstate Judgment in this Case Meanwhile, this action remained stayed. In September 2020, the respondent moved this Court to lift the stay and reissue final judgment. Dkt. 58. The Court lifted the stay and directed

Mr. Holmes to show cause why the action should not be dismissed for lack of jurisdiction as an unauthorized second or successive petition. Dkt. 61. Mr. Holmes responded by filing duplicate motions to stay proceedings. Dkt. 76; dkt. 79. II. Discussion A.

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Related

Holmes v. Levenhagen
600 F.3d 756 (Seventh Circuit, 2010)
Atkins v. Virginia
536 U.S. 304 (Supreme Court, 2002)
Michael Allen Lambert v. Cecil Davis, Superintendent
449 F.3d 774 (Seventh Circuit, 2006)
Ryan v. Valencia Gonzales
133 S. Ct. 696 (Supreme Court, 2013)
Holmes v. State
820 N.E.2d 136 (Indiana Supreme Court, 2005)
Saylor v. Indiana
808 N.E.2d 646 (Indiana Supreme Court, 2004)
State v. Holmes
728 N.E.2d 164 (Indiana Supreme Court, 2000)
Ben-Yisrayl v. Buss
540 F.3d 542 (Seventh Circuit, 2008)
Holmes v. State
671 N.E.2d 841 (Indiana Supreme Court, 1996)
Minnick v. State
965 N.E.2d 124 (Indiana Court of Appeals, 2012)

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Bluebook (online)
HOLMES v. NEAL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holmes-v-neal-insd-2023.