Jackson v. United States

CourtDistrict Court, D. Arizona
DecidedMarch 27, 2025
Docket3:24-cv-08126
StatusUnknown

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

Bluebook
Jackson v. United States, (D. Ariz. 2025).

Opinion

1 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 United States of America, No. CV 24-08126-PCT-DJH (MTM)

10 Plaintiff, No. CR 17-08242-PCT-DJH

11 v. REPORT AND RECOMMENDATION

12 Giordano Jackson,

13 Defendant/Movant. 14 15 TO THE HONORABLE DIANE J. HUMETEWA, UNITED STATES DISTRICT 16 JUDGE: 17 Movant Jackson, who is confined in the United States Penitentiary in Louisiana, 18 filed a Motion under 28 U.S.C. § 2255 to Vacate, Set Aside, or Correct Sentence. Doc. 1. 19 I. SUMMARY OF CONCLUSION 20 Movant was convicted of first-degree murder and multiple counts of assault. 21 Movant is barred from relief under 28 U.S.C. § 2255 because he raises the same issue – 22 arising from the prosecutor’s Closing Argument at trial – previously litigated on direct 23 appeal. This Court will recommend that the Motion be denied and dismissed with 24 prejudice. 25 II. BACKGROUND 26 A. Conviction and Sentencing 27 On November 12, 2018, in Arizona District Court, Movant was found guilty at trial 28 of First-Degree Murder, Assault Resulting in Serious Bodily Injury, and two counts of 1 Assault with a Dangerous Weapon. CR 105.1 At trial, the prosecution proved a prior 2 romantic relationship between Movant and the victim and documented the victim’s 3 extensive and fatal wounds. United States v. Jackson, 2022 WL 331687, at *1 (9th Cir. Feb. 4 3, 2022). Movant was sentenced on February 25, 2019 to life imprisonment for his first 5 degree murder conviction, and several concurrent terms of 120 months on other counts of 6 conviction. CR 137. 7 B. Direct Appeal 8 Movant timely appealed his conviction and sentence. Alleging prosecutorial 9 misconduct, Movant asserted that the prosecutor in Closing Argument had “misstated 10 evidence, argued matters not in evidence, exceeded the bounds of fair argument, and 11 wrongly deployed inflammatory rhetoric to emotionally incite the jury.” CA9 36 at 64 12 [Appellant’s Opening Brief].2 The Ninth Circuit found that the prosecutor had not 13 committed misconduct. Jackson, 2022 WL 331687 at *2. In a separate opinion, the Ninth 14 Circuit remanded for resentencing because it reversed Movant’s conviction for a prior 15 kidnapping of the murder victim. United States v. Jackson, 24 F.4th 1308, 1315 (9th Cir. 16 2022). Movant was resentenced on September 20, 2022 to life imprisonment for his first 17 degree murder conviction as well as concurrent terms of 120 months for three counts of 18 assault. CR 182. Movant filed a timely Notice of Appeal. CR 185. On April 26, 2023 the 19 Ninth Circuit, after an independent review of the record in an Anders appeal, found that 20 Movant had not presented any arguable grounds for relief. CR 192. 21 III. MOTION PURSUANT TO 28 U.S.C. § 2255 22 On June 24, 2024, Movant filed his Motion under 28 U.S.C. § 2255. As summarized 23 by this Court, Movant asserts he received ineffective assistance of counsel based on trial 24 counsel’s failure to object to prosecutorial misconduct during the prosecutor’s closing 25 argument. Doc. 4. The United States filed a limited Response on September 17, 2024. Doc. 26 5. Movant replied on October 17, 2024. Doc. 6.

27 1 CR cites are to the district court docket. 28 2 CA9 cites are to the Ninth Circuit docket. 1 As noted by the United States in its Response (doc. 5 at 8), Movant’s argument in 2 his 28 U.S.C. § 2255 Motion repeats - word for word - his argument from his Opening 3 Brief in his direct appeal of his first sentencing. See CA9 36 at 64. As he stated in his 4 Opening Brief in his direct appeal, Movant again states:

5 the prosecutor misstated evidence, argued matters not in evidence, exceeded the bounds of fair argument, and wrongly 6 deployed inflammatory rhetoric to emotionally incite the jury.

7 Doc. 2 at 6. Further, Movant’s supporting arguments in his § 2255 Motion, except for a 8 few re-worded subheadings, are also a word for word repeat of his arguments from his 9 Opening Brief on direct appeal. See Doc. 2 at 6-14 and his appellate brief at 54-61 from 10 CA9 36. 11 Respondent asserts that the Motion violates a relitigation bar, because Movant’s 12 “claim of error on appeal – alleged prosecutorial misconduct in closing argument – mirrors 13 exactly the error he now claims his counsel should have objected to.” Doc. 5 at 9. 14 Relitigation Bar 15 In Movant’s direct appeal, the 9th Circuit considered whether the prosecutor’s 16 Closing Argument was misconduct: 17 [Movant] argues that the government committed misconduct in 18 its closing arguments by alleging that [Movant], inter alia, searched for the murder weapon in his house, started beating 19 the victim in his house, enjoyed domestic abuse, and lied about being intoxicated at the time of the murder. 20

21 * * *

22 The government’s arguments that [Movant] lied were not misconduct. In a case like this one that “essentially reduces to 23 which of two conflicting stories is true,” it is not unreasonable to argue “that one of the two sides is lying.” The government’s 24 graphic descriptions about [Movant’s] proclivities for domestic abuse present a closer call, but on balance, those 25 arguments were “hard blows” tied to “reasonable inferences from the evidence.” The government’s statements 26 about [Movant’s] conduct in his home—searching for the weapon and beating the victim there – are arguably grounded 27 in guesswork rather than inferences and evidence. Nonetheless, [Movant] cannot establish plain error: Given 28 “the evidence supporting the jury’s verdict, we do not believe 1 that permitting that verdict to stand constitutes a miscarriage of justice.” 2 3 Jackson, 2022 WL 331687 at *2 (internal citations omitted, emphasis added). 4 The “law of the case” governing Movant’s § 2255 motion, as established by the 9th 5 Circuit on direct appeal, is that the government’s Closing Argument was not misconduct 6 and not plain error. Accordingly, Movant is barred from relitigating whether the 7 prosecutor’s Closing Argument constituted objectionable misconduct. See Egger v. United 8 States, 509 F.2d 745, 748 (9th Cir. 1975) and United States v. Ramirez, 327 Fed. App’x 9 751, 752 (9th Cir. 2009). 10 In his Reply, Movant asserts that his Motion is not barred, as he asserts it was 11 ineffective assistance of counsel for his counsel not to object to the same words in Closing 12 Argument that he argued on direct appeal were prosecutorial misconduct. Doc. 6 at 1-2. 13 As a practical matter, Movant’s argument fails, despite the new legal label he gives it, 14 because his trial counsel’s failure to object to the prosecutor’s argument was not ineffective 15 assistance under Strickland v. Washington, 466 U.S. 668, 687 (1984), where the 16 prosecutor’s argument was not in fact misconduct. See Rupe v. Wood, 93 F.3d 1434, 1145 17 (9th Cir. 1996) (it is not deficient performance for trial counsel to fail to take a futile act), 18 and Jones v. Ryan, 691 F.3d 1093, 1101 (9th Cir.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Robert S. Egger v. United States
509 F.2d 745 (Ninth Circuit, 1975)
United States v. Mark Edward Currie
589 F.2d 993 (Ninth Circuit, 1979)
Robert Jones, Jr. v. Charles Ryan
691 F.3d 1093 (Ninth Circuit, 2012)
United States v. Giordano Jackson
24 F.4th 1308 (Ninth Circuit, 2022)
Rupe v. Wood
93 F.3d 1434 (Ninth Circuit, 1996)

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Jackson v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-united-states-azd-2025.