Jefferson v. Russell

CourtDistrict Court, D. Nevada
DecidedSeptember 22, 2020
Docket3:19-cv-00331
StatusUnknown

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

Bluebook
Jefferson v. Russell, (D. Nev. 2020).

Opinion

5 UNITED STATES DISTRICT COURT 6 DISTRICT OF NEVADA 7 * * * 8 ANDRUE JEFFERSON, Case No. 3:19-cv-00331-RCJ-WGC 9 Petitioner, 10 v. ORDER

11 PERRY RUSSELL, et al., 12 Respondents. 13 14 15 This is a habeas corpus proceeding under 28 U.S.C. § 2254. Respondents have 16 filed a motion to dismiss (ECF No. 10) in response to Jefferson’s petition for writ of 17 habeas corpus (ECF No. 6). Respondents argue that several of Jefferson’s claims must 18 be dismissed because they are either not cognizable in a federal habeas proceeding or 19 they have not been exhausted in state court. Respondents also argue that one of 20 Jefferson’s claims should be dismissed as conclusory. For reasons that follow, the 21 motion will be granted, in part, and denied, in part. 22 I. BACKGROUND1 23 On December 12, 2012, following a jury trial in Nevada’s Second Judicial District 24 Court, in Washoe County, Jefferson was found guilty of murder in the second degree. 25 He was sentenced to life in prison with parole eligibility after serving a minimum of 10 26 1 The following background information was gathered from the exhibits filed at ECF Nos. 11-13 and this 27 court’s own docket. 1 years. Jefferson appealed, and the Nevada Supreme Court affirmed the judgment on 2 February 27, 2014. 3 On March 4, 2015, Jefferson filed a petition for a writ of habeas corpus in the 4 state district court. With the assistance of court-appointed counsel, Jefferson filed a 5 supplemental petition. After holding an evidentiary hearing in December 2017, the court 6 denied habeas relief. Jefferson appealed. On April 16, 2019, the Nevada Court of 7 Appeals entered an order affirming the lower court’s decision. 8 This court received Jefferson’s habeas petition with a motion to proceed in forma 9 pauperis on June 18, 2019. After Jefferson paid the filing fee, the court screened the 10 petition and ordered that it be filed on August 5, 2019. On November 18, 2019, 11 respondents filed the motion to dismiss now before the court for decision. 12 II. COGNIZABILIITY 13 Respondents argue that part of Ground 1(B), Ground 1(C), and Ground 1(D) are 14 not cognizable in a federal habeas proceeding. 15 A petition for a writ of habeas corpus is only available if a person is being held in 16 custody in violation of the Constitution or laws or treaties of the United States. 28 U.S.C. 17 § 2254(a). A federal writ of habeas corpus is not available with respect to claims based 18 solely on alleged errors in the interpretation or application of state law. Wilson v. 19 Corcoran, 562 U.S. 1, 5 (2010). To obtain habeas relief, a petitioner must demonstrate 20 a transgression of federal law binding on the state courts. Id. Thus, if the petitioner's 21 claim is premised merely on an alleged misapplication of state law, he fails to state a 22 cognizable claim for federal habeas relief. See Lewis v. Jeffers, 497 U.S. 764, 780 23 (1990). 24 In Ground 1, Jefferson presents, verbatim, the arguments he presented to the 25 Nevada Supreme Court in his direct appeal. ECF No. 6 at 3-17; ECF No. 12-23 at 7-21. 26 His claim in Ground 1(A) and (B) that the evidence presented was not sufficient to 27 sustain a conviction of second-degree murder is based on an alleged violation of the 1 Due Process Clause as recognized in Jackson v. Virginia, 443 U.S. 307 (1979). ECF 2 No. 6 at 7-14. Thus, it is cognizable in this proceeding. He also presents a cognizable 3 claim that the prosecution’s presentation of gang-related evidence argument without 4 advance notice violated his federal right to due process. Id. Jefferson’s remaining 5 arguments in Ground 1(B) are premised on alleged violations of state law and are, 6 therefore, not cognizable in a federal habeas proceeding. Id. 7 Ground 1(C) alleges the trial court erred in instructing the jury on the theory of 8 aiding and abetting second degree murder. Id. at 14-16. Ground 1(D) alleges the trial 9 court erred in refusing to grant the defense additional peremptory challenges. These 10 claims are premised entirely on alleged violations of state law. Id. at 16-17. Thus, they 11 will be dismissed as not cognizable in a federal habeas proceeding.2 12 III. EXHAUSTION 13 Respondents argue that Jefferson has failed to exhaust state court remedies for 14 most of Grounds 2 and 3. 15 a. Standards. 16 A federal court will not grant a state prisoner's petition for habeas relief until the 17 prisoner has exhausted his available state remedies for all claims raised. Rose v. 18 Lundy, 455 U.S. 509 (1982); 28 U.S.C. § 2254(b). A petitioner must give the state 19 courts a fair opportunity to act on each of his claims before he presents those claims in 20 a federal habeas petition. O'Sullivan v. Boerckel, 526 U.S. 838, 844 (1999). A claim 21 remains unexhausted until the petitioner has given the highest available state court the 22 opportunity to consider the claim through direct appeal or state collateral review 23 proceedings. See Casey v. Moore, 386 F.3d 896, 916 (9th Cir. 2004); Garrison v. 24 McCarthey, 653 F.2d 374, 376 (9th Cir.1981). 25 2 In Ground 4, Jefferson alleges that he “reserve[s] the right to set forth additional claims of 26 ineffectiveness of trial and/or appellate counsel.” ECF No. 6 at 86. Because it does not constitute an independent ground upon which federal habeas relief may be granted, it will also be dismissed as not 27 cognizable. 1 A habeas petitioner must “present the state courts with the same claim he urges 2 upon the federal court.” Picard v. Connor, 404 U.S. 270, 276 (1971). To achieve 3 exhaustion, the state court must be “alerted to the fact that the prisoner [is] asserting 4 claims under the United States Constitution” and given the opportunity to correct alleged 5 violations of the prisoner's federal rights. Duncan v. Henry, 513 U.S. 364, 365 (1995); 6 see Hiivala v. Wood, 195 F.3d 1098, 1106 (9th Cir. 1999). 7 A claim is not exhausted unless the petitioner has presented to the state court 8 the same operative facts and legal theory upon which his federal habeas claim is based. 9 Bland v. California Dept. of Corrections, 20 F.3d 1469, 1473 (9th Cir. 1994). The 10 exhaustion requirement is not met when the petitioner presents to the federal court facts 11 or evidence which place the claim in a significantly different posture than it was in the 12 state courts, or where different facts are presented at the federal level to support the 13 same theory. See Nevius v. Sumner, 852 F.2d 463, 470 (9th Cir. 1988). On the other 14 hand, new allegations that do not “fundamentally alter the legal claim already 15 considered by the state courts” will not render a claim unexhausted. Vasquez v. Hillery, 16 474 U.S. 254

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404 U.S. 270 (Supreme Court, 1971)
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431 U.S. 63 (Supreme Court, 1977)
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Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Vasquez v. Hillery
474 U.S. 254 (Supreme Court, 1986)
Lewis v. Jeffers
497 U.S. 764 (Supreme Court, 1990)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Duncan v. Walker
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Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Wilson v. Corcoran
131 S. Ct. 13 (Supreme Court, 2010)
Jerry W. Garrison v. D. J. McCarthy Superintendent
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Jefferson v. Russell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jefferson-v-russell-nvd-2020.