Joel Aguilar v. A. Sullivan

CourtDistrict Court, C.D. California
DecidedJanuary 17, 2020
Docket8:19-cv-00539
StatusUnknown

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

Bluebook
Joel Aguilar v. A. Sullivan, (C.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 JOEL AGUILAR, ) Case No. SACV 19-0539-JPR 11 ) Petitioner, ) MEMORANDUM DECISION AND ORDER 12 ) DENYING PETITION AND DISMISSING v. ) ACTION WITH PREJUDICE 13 ) WILLIAM SULLIVAN, Acting ) 14 Warden,1 ) ) 15 Respondent. ) ) 16 17 PROCEEDINGS 18 On March 19, 2019, Joel Aguilar, proceeding pro se, filed a 19 Petition for Writ of Habeas Corpus by a Person in State Custody 20 and accompanying memorandum of points and authorities, raising a 21 single claim challenging his 2016 convictions for attempted 22 murder and related crimes. Respondent filed his Answer and 23 accompanying memorandum of points and authorities on April 17, 24 1 Petitioner is incarcerated at the California Correctional 25 Institution, see Cal. Dep’t Corr. & Rehab. Inmate Locator, https:// 26 inmatelocator.cdcr.ca.gov (search for “Aguilar” with “Joel”) (last visited Jan. 16, 2020), whose acting warden is William Sullivan. 27 He is therefore substituted in as the correct respondent. See Fed. R. Civ. P. 25(d); see also R. 2(a), Rs. Governing § 2254 Cases in 28 U.S. Dist. Cts. 1 1 2019, to which Petitioner has not replied. For the reasons 2 discussed below, the Petition is denied and this action is 3 dismissed with prejudice. 4 BACKGROUND 5 In February 2016, Petitioner was convicted by an Orange 6 County Superior Court jury of premeditated attempted murder, 7 conspiracy to commit murder, active participation in a criminal 8 street gang, and possession of a firearm by a prohibited person. 9 (Lodged Doc. 1, 3 Rep.’s Tr. at 617-20; Lodged Doc. 2, 4 Clerk’s 10 Tr. at 911, 913, 915-16, 961, 963.) The jury found true various 11 gang and firearm enhancements. (Lodged Doc. 1, 3 Rep.’s Tr. at 12 618-19; Lodged Doc. 2, 4 Clerk’s Tr. at 911-14, 961.) On March 13 4, 2016, the court sentenced Petitioner to a prison term of 110 14 years to life. (Lodged Doc. 2, 4 Clerk’s Tr. at 962.) 15 On June 30, 2016, the California Supreme Court decided 16 People v. Sanchez, 63 Cal. 4th 665 (2016), holding that 17 “case-specific out-of-court statements” relied on by a 18 prosecution gang expert are inadmissible hearsay under California 19 law and may also violate a defendant’s Sixth Amendment right to 20 confrontation. Id. at 686. Petitioner appealed, arguing that 21 the trial court improperly admitted testimonial hearsay from the 22 prosecution’s gang expert, violating Sanchez and the 23 Confrontation Clause (Lodged Doc. 4 at 30-45), among other 24 claims. On December 27, 2017, the court of appeal rejected all 25 his claims in a reasoned decision on the merits and affirmed the 26 judgment. (See Lodged Doc. 7); People v. Aguilar, No. G053262, 27 2017 WL 6602368 (Cal. Ct. App. Dec. 27, 2017). The court found 28 that Petitioner’s Sanchez claim failed because he had forfeited 2 1 it, some of the evidence was not hearsay, and any error was 2 harmless. (Lodged Doc. 7 at 9-15); Aguilar, 2017 WL 6602368, at 3 *7-8. On April 11, 2018, the state supreme court summarily 4 denied his petition for review raising the same claims. (See 5 Lodged Docs. 8, 9.) He did not petition for certiorari in the 6 U.S. Supreme Court (Pet. at 5) or file any state habeas petitions 7 (id. at 3). 8 PETITIONER’S CLAIM 9 The admission of the gang expert’s testimony at trial 10 violated Petitioner’s Sixth Amendment right of confrontation. 11 (Pet. at 5 & Mem. P. & A. at 1.) 12 SUMMARY OF THE EVIDENCE 13 The factual summary in a state appellate-court decision is 14 entitled to a presumption of correctness under 28 U.S.C. 15 § 2254(e)(1). See Thompson v. Runnels, 705 F.3d 1089, 1091-92 16 (9th Cir. 2013). Although Petitioner does not challenge the 17 sufficiency of the evidence, the Court has nonetheless 18 independently reviewed the state-court record. Based on that 19 review, the Court finds that the following statement of facts 20 from the California Court of Appeal decision is a fair and 21 accurate summary of the evidence presented at trial. 22 On July 22, 2014, around 11:30 p.m., Maria V. parked 23 her car on West Myrtle Street in Santa Ana to pick up one 24 of her children from a babysitter, her boyfriend’s 25 cousin. After another vehicle passed by going in the 26 opposite direction, she heard a “couple [gun]shots.” 27 Maria, her 10–year–old son, and the cousin, who was a 28 nurse, approached the male victim and found he had been 3 1 wounded, but survived the shooting. At trial, Maria 2 claimed she did not recognize the victim. At the 3 preliminary hearing, she stated she had seen him around 4 the Myrtle Street area but had never spoken with 5 him.[FN1] 6 [FN1] Maria also testified at the preliminary 7 hearing that she grew up with the defendant, 8 [Petitioner], who was her brothers’ friend. 9 The Townsend Street gang claimed their 10 neighborhood as its territory, and she and 11 her four brothers belonged to the gang 12 (hereafter “Townsend Street gang” or just 13 “Townsend”). Her nickname was “Cookie,” and 14 she implied [Petitioner] also belonged to 15 the gang, testifying his moniker or nickname 16 was “Bam Bam.” Maria stopped hanging out 17 with the gang several years before the 18 shooting. She admitted her children’s 19 father had belonged to another gang for 20 several years, West Myrtle, a Townsend 21 rival. 22 Maria called 911 to report the shooting about 40 23 minutes after it occurred, requesting anonymity. She 24 told the 911 operator she saw the shooting. The 25 assailants rode in a four-door blue Ford Explorer driven 26 by “Little Casper,” a Townsend gang member later 27 identified as Alberto Santana. Bam Bam, who Maria 28 referred to as “Julio” Aguilar at one point in the 911 4 1 call, rode in the back seat and “did the shooting.” She 2 physically described the men, noting [Petitioner] had 3 Townsend tattoos “everywhere” including his neck and 4 hands,[FN2] and she provided an address for Santana. She 5 told the operator she had seen the men in a group at 805 6 South Townsend after the shooting. 7 [FN2] [Petitioner] did not have Townsend tattoos 8 on his hands. Also, the tattoos on his neck 9 referred to “Southwest,” not Townsend. 10 Maria also apparently misdescribed Santana 11 as tall. 12 Detective Charles Elms and his partner interviewed 13 Maria two days after the shooting, and the prosecution 14 played a recording of the interview for the jury. In the 15 interview, Maria reluctantly admitted making the 911 16 call, after remarking “why would [she] want to snitch” on 17 her brothers’ and “baby daddy’s” neighborhoods. She told 18 the officers she could not “say any more” because she was 19 at “risk of a lot of things,” noting her family and 20 “everybody . . . already knows I was there.” She worried 21 her name would appear in the “paperwork,” citing other 22 witnesses who had been killed. 23 Nonetheless, she identified photos of Little Casper 24 and Bam Bam, and later admitted in court that Bam Bam was 25 [Petitioner]. She further described in the interview 26 some details about the shooting, including that 27 [Petitioner] used a revolver and she heard six shots. 28 She told the officers she called 911 because she was 5 1 angry the shooting occurred in her children’s presence, 2 and the perpetrators had “no respect for families and 3 kids.” After the shooting, she went “straight over” to 4 the 805 Townsend Street address, where a group had 5 assembled, and yelled at [Petitioner]. [Petitioner] was 6 not apologetic, claiming only that he did not know she 7 was there.

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Joel Aguilar v. A. Sullivan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joel-aguilar-v-a-sullivan-cacd-2020.