James E. Raines v. Jay Forshey, Warden, Noble Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedNovember 10, 2025
Docket2:25-cv-00116
StatusUnknown

This text of James E. Raines v. Jay Forshey, Warden, Noble Correctional Institution (James E. Raines v. Jay Forshey, Warden, Noble Correctional Institution) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James E. Raines v. Jay Forshey, Warden, Noble Correctional Institution, (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

JAMES E. RAINES,

Petitioner, : Case No. 2:25-cv-116

- vs - District Judge Douglas R. Cole Magistrate Judge Michael R. Merz

JAY FORSHEY, Warden, Noble Correctional Institution,

: Respondent. SUPPLEMENTAL REPORT AND RECOMMENDATIONS

This habeas corpus action, brought pro se by Petitioner James Raines under 28 U.S.C. § 2254, is before the Court on Petitioner’s Objections (“Objections,” ECF No. 19) to the Magistrate Judge’s Report and Recommendations recommending dismissal (“Report,” ECF No. 18). District Judge Cole has recommitted the case to the undersigned for reconsideration in light of the Objections (ECF No. 20). Petitioner does not object to the recitation of litigation history in the Report and it will not be repeated here.

Ground One: Ineffective Assistance of Trial Counsel

In his first Ground for Relief, Petitioner asserts he received ineffective assistance of trial counsel when his trial attorney failed to realize that Petitioner had been charged under the incorrect violation of a protective order statute and recommended a guilty plea to that charge, whereas he would have had a complete defense and would have gone to trial if the advice had been correct. The Report accepts Respondent’s defense this Ground for Relief is procedurally defaulted because the adverse decision of the Fourth District Court of Appeals on this claim was not appealed

to the Ohio Supreme Court (Report, ECF No. 18, citing Return of Writ, ECF No. 11, PageID 392). Petitioner objects that the omission of this claim from the appeal to the Ohio Supreme Court is the fault of the retained attorney who represented him in that court in not including it (Objections, ECF No. 19, PageID 452). The record shows Raines was represented by the same retained attorney in both the Fourth District Court of Appeals and the Ohio Supreme Court (See State Court Record, ECF No. 10, Appellant Brief, Ex. 20; Memorandum in Support of Jurisdiction, Ex.29). Petitioner argues that in that circumstance ''no competent counsel, in the exercise of reasonable professional judgement, would have omitted the claim[s]." Objections, ECF No. 19, PageID 452, quoting Hittson v. GDCP

Warden, 159 F.3d 1210, 1263-66 (11th Cir., Jul. 9, 2014). The words Raines quotes do indeed appear in the Hittson opinion, but he has taken them out of context. They were written by the Eleventh Circuit to describe a standard of proof for ineffective assistance of trial counsel claims, not to show that Hittson had met that standard. The Court wrote: [T]o show that his habeas counsel failed to provide the level of representation required by Strickland [v. Washington, 466 U.S. 668 (1984)], Hittson must show more than the mere fact they failed to raise potentially meritorious claims; he must show that no competent counsel, in the exercise of reasonable professional judgment, would have omitted those claims. Even assuming that the underlying ineffective-assistance claims are meritorious (which, as we explain in the following section, they are not), Hittson has not established that his state habeas counsel were incompetent for failing to raise them.

459 F.3d at 1263.

It is clear that Raines’ claim of ineffective assistance of trial counsel was not presented to the Ohio Supreme Court on direct appeal. Thus that claim is procedurally defaulted under O'Sullivan v. Boerckel, 526 U.S. 838, 846-7(1999), which requires that any habeas claim be presented to a full round of state court consideration. An unexcused procedural default will bar a claim in habeas. The Report found Petitioner had not presented excusing cause and prejudice. In his Objections Petitioner relies on a claim of ineffective assistance of appellate counsel, asserting it was ineffective assistance of appellate counsel to omit this claim. But as the Report also concluded ineffective assistance of counsel will only count as excusing cause if it occurs in a proceeding where the Sixth Amendment guarantees effective assistance of counsel. Appeal to the Ohio Supreme Court is not such a proceeding because it is not an appeal of right. Pennsylvania v. Finley, 481 U.S. 551, 555 (1987); Ross v. Moffitt, 417 U.S. 600 (1974). Ineffective assistance of counsel can excuse procedural default only when it occurs in a proceeding where a defendant is constitutionally entitled to counsel under the Sixth Amendment. Wainwright v. Torna, 455 U.S. 586 (1982)(where there is no constitutional right to counsel there can be no deprivation of effective counsel); Riggins v. Turner, 1997 U.S. App. LEXIS 6115, *5 (6th Cir. 1997); Barkley v. Konteh, 240 F. Supp. 2d 708, 714 (N.D. Ohio 2002). Petitioner relies on the proposition ''Inadequate assistance of counsel at [the States Highest Court] proceedings may establish cause for a prisoner's procedural default of a claim of ineffective assistance at trial." Objections, ECF No. 19, PageID 454, citing Martinez v. Ryan, 566 U.S. 1, 132 S. Ct. 1309, 1315 (2012). The word Petitioner has added in brackets do not reflect the Supreme Court’s holding. In Martinez, the Supreme Court held ineffective assistance of counsel in collateral challenges to a conviction can act as excusing cause for failure to present a claim in those proceedings “when a State requires a prisoner to raise a claim of ineffective assistance at trial in a collateral proceeding.” 566 U.S. at 1312 (emphasis added). Arizona is such a State, but Ohio is

not. Ineffective assistance of trial counsel claims in Ohio which can be adjudicated on the appellate record must be litigated on direct appeal or be held barred by res judicata. In State v. Perry, 10 Ohio St. 2d 175 (1967). The Sixth Circuit has held explicitly that Martinez does not apply in Ohio. Moore v. Mitchell, 708 F. 3d 760 (6th Cir. 2013).

Ground Two: Denial of Due Process: Guilty Plea Not Knowing, Intelligent, and Voluntary

In his Second Ground for Relief, Raines contends his guilty plea was not knowing, intelligent, and voluntary and therefore his conviction of the basis of that plea violates his Due

Process rights under the Fourteenth Amendment. The Report quoted at length from the Fourth District’s rejection of this claim on direct appeal (ECF No. 16, PageID 441-46) and concluded that decision was not an objectively unreasonable application of clearly established Supreme Court precedent. Id. at PageID 447. Petitioner objects that the Fourth District’s decision is not entitled to deference because it was “authored by the prosecuting attorney.” To attempt to prove that fact, Petitioner cites the dissenting opinion of Justice Donnelly in a capital case, State v. Bonnell, 159 Ohio St. 3d 1413 (2020). Petitioner goes further: “The State of Ohio is notorious for walking around arguments, ·providing red herrings and strawman arguments when it comes to constitutional issues in criminal cases.” (Objections, ECF No. 19, PageID 456). This is irrelevant and unsubstantiated rhetoric. There is absolutely no proof that the Fourth District’s opinion was drafted by the prosecuting attorney. Petitioner claims he was promised probation by his attorney if he pleaded guilty.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Ross v. Moffitt
417 U.S. 600 (Supreme Court, 1974)
Wainwright v. Torna
455 U.S. 586 (Supreme Court, 1982)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Pennsylvania v. Finley
481 U.S. 551 (Supreme Court, 1987)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
Barkley v. Konteh
240 F. Supp. 2d 708 (N.D. Ohio, 2002)
Lee Moore v. Betty Mitchell
708 F.3d 760 (Sixth Circuit, 2013)
State v. Perry
226 N.E.2d 104 (Ohio Supreme Court, 1967)

Cite This Page — Counsel Stack

Bluebook (online)
James E. Raines v. Jay Forshey, Warden, Noble Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-e-raines-v-jay-forshey-warden-noble-correctional-institution-ohsd-2025.