Jeffrey S. Renzi v. Commonwealth of Virginia

794 F.2d 155, 1986 U.S. App. LEXIS 26405
CourtCourt of Appeals for the Fourth Circuit
DecidedJune 25, 1986
Docket85-6484
StatusPublished
Cited by10 cases

This text of 794 F.2d 155 (Jeffrey S. Renzi v. Commonwealth of Virginia) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeffrey S. Renzi v. Commonwealth of Virginia, 794 F.2d 155, 1986 U.S. App. LEXIS 26405 (4th Cir. 1986).

Opinions

HAYNSWORTH, Senior Circuit Judge:

In the Circuit Court of Fairfax County, Virginia, a jury found Renzi guilty of possession of phencyclidine (PCP) and specified his punishment to be twenty years imprisonment and a fine of $1,000.

After a direct appeal proved unavailing, Renzi sought a writ of habeas corpus in the United States District Court for the Eastern District of Virginia. That court granted the writ upon a finding that Renzi’s trial [157]*157had been so unfair as to amount to a deprivation of due process.

I.

On October 7, 1982, Fletcher, a confidential informant, arranged a meeting between Kreitzer, a police official working undercover, and Renzi so that Kreitzer could buy PCP from Renzi.

According to Kreitzer, Fletcher drove into a High’s parking lot with Renzi in the front passenger seat. Kreitzer got into the back, and Fletcher drove off. Renzi had a plastic bag containing a green plant-like material, and Renzi and Kreitzer negotiated for the sale of two “cans” of PCP by Renzi to Kreitzer. Renzi measured the requested amount, placed it in another plastic bag, and gave it to Kreitzer. In return, Kreitzer paid Renzi $100 as Renzi assured him that the PCP was of excellent quality.

The entire transaction took no more than two minutes, after which Kreitzer was let out at the parking lot and Fletcher and Renzi drove off.

Renzi took the stand in his own defense and told a very different story. Renzi testified that he had been called by Fletcher and offered a job as a painter. Fletcher picked him up for the purpose, Renzi thought, of taking him to the job site. Fletcher made a stop at a house that was unfamiliar to Renzi, went inside and returned with a container which he placed beneath the driver’s seat. Fletcher then told Renzi that they had to pick up another painter. The third person, of course, was Kreitzer.

Renzi’s testimony was in general agreement with Kreitzer’s about the meeting in the parking lot and the taking of a two minute ride after which Kreitzer was returned to the parking lot. His version of what happened during that ride, however, differed markedly from Kreitzer’s. He testified that the sale of the two cans of PCP was effected by Fletcher. Renzi’s version was that Fletcher negotiated the sale. Fletcher then reached beneath the driver’s seat and passed a plastic bag to Renzi with instructions to measure out two cans of the vegetable material for Kreitzer. Renzi did that and received $100 from Kreitzer but immediately passed the money on to Fletcher. Thus, according to Renzi, he was not the principal; he only supplied requested manual assistance to Fletcher.

Renzi testified that Fletcher never performed his promise of painting employment.

II.

During a discovery hearing, Renzi moved to require the Commonwealth to produce the name and address of its confidential informant. The Commonwealth’s Attorney responded that if any confidential informant had been present at the drug buy, he would be “put under subpoena to appear.” Renzi’s lawyer requested that the informant be produced before trial so that he might be interviewed before testifying. The judge responded to that, expressing confidence that the Commonwealth’s Attorney “can work something out to get him here early that morning sometime so you can talk to him. You’ll have plenty of time to talk to him.”

The Commonwealth did not subpoena Fletcher, but, six days before trial, the Commonwealth gave Renzi’s lawyer Fletcher’s name and an address. Renzi promptly arranged for the issuance of a subpoena, but, on the morning that the trial was to begin, found that the subpoena had been returned marked “Not Found.” Renzi elected to proceed with the trial despite Fletcher’s absence. The lawyer now says that he thought the Commonwealth would still produce Fletcher for examination and cross-examination. He was not produced, and, on hearsay grounds, Renzi was not permitted to testify as to any statements made to him by Fletcher.

At a post-trial hearing upon Renzi’s motion for a new trial based upon after discovered evidence, it appeared that Fletcher had been in the drug business. He had experienced a religious conversion and wished to make amends for some of his past transgressions. He became a confi[158]*158dential informant and arranged transactions resulting in the arrest of approximately thirty drug dealers.

At the post-trial hearing, Kreitzer testified that when he gave the address to the Commonwealth’s Attorney he thought Fletcher was no longer there; he thought Fletcher had left the area, which well might have been the case, but the address he supplied was the last one he had.

III.

The Commonwealth first contends that Renzi has not adequately exhausted his state remedies, and that the petition for a federal writ of habeas corpus is premature for that reason. It points to the fact that Renzi’s petition for a writ of error charged that the trial court erred in denying a motion for a new trial based upon after discovered evidence. It contends that the identical federal question sought to be presented here was not first presented to the Supreme Court of Virginia.

The contention rests too narrowly upon the caption of the argument presented to the Supreme Court of Virginia and neglects a critical part of its substance. The after discovered evidence that was the foundation of the motion was said to have been the fact that the Commonwealth failed to produce Fletcher during the trial as it had promised, and that it misled Renzi as to Fletcher’s whereabouts. The brief stated all of the relevant facts upon which Renzi relies here. It specifically contended that Renzi “was denied his due process rights by his inability to get ... [Fletcher’s] testimony.” Finally, there was a citation to Roviaro v. United States, 353 U.S. 53, 77 S.Ct. 623, 1 L.Ed.2d 639 (1957), in which the Supreme Court had held that when an undercover informer was a participant in, or witness to, a crime and the testimony of the informer would be of substantial help to the defendant, the privilege to withhold disclosure of his identity must give way and a trial without this testimony was so unfair as to amount to a deprivation of due process. Id. at 64-65, 77 S.Ct. at 629-30. Renzi’s contention was substantially the same as that made in Roviaro. Citation of that case to the Supreme Court of Virginia, coupled with the explicit claim of deprivation of due process, was a sufficient presentation of the federal claim to the state court.

The exhaustion requirement exists, as a matter of comity, to give the state court the first opportunity to adjudicate alleged constitutional defects in its own criminal prosecutions. See Rose v. Lundy, 455 U.S. 509, 518, 102 S.Ct. 1198, 1203, 71 L.Ed.2d 379 (1982), citing Duckworth v. Serrano, 454 U.S. 1, 3, 102 S.Ct. 18, 19, 70 L.Ed.2d 1 (1981) (per curiam). State remedies are sufficiently exhausted when the state court is given a “ ‘fair opportunity’ to apply controlling legal principles to the facts bearing upon ... [a] constitutional claim” by fair presentation of the “substance” of the federal claim. Anderson v. Harless, 459 U.S. 4, 6, 103 S.Ct. 276, 277, 74 L.Ed.2d. 3, quoting Picard v.

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Bluebook (online)
794 F.2d 155, 1986 U.S. App. LEXIS 26405, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeffrey-s-renzi-v-commonwealth-of-virginia-ca4-1986.