Johnson v. Gadson

CourtDistrict Court, D. South Carolina
DecidedMay 6, 2025
Docket4:23-cv-01045
StatusUnknown

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

Bluebook
Johnson v. Gadson, (D.S.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION

Brittany Johnson, ) Case No.: 4:23-cv-01045-JDA ) Petitioner, ) ) v. ) OPINION AND ORDER ) Devin Gadson, Warden of Camille )

Griffin Graham Correctional Institution, ) ) Respondent. ) )

Petitioner, a state prisoner represented by counsel, seeks habeas corpus relief pursuant to 28 U.S.C. § 2254. This matter is before the Court on Respondent’s motion for summary judgment. [Doc. 13.] In accordance with 28 U.S.C. § 636(b) and Local Civil Rule 73.02(B)(2), D.S.C., this matter was referred to United States Magistrate Judge Thomas E. Rogers, III, for pre-trial proceedings. On December 27, 2023, the Magistrate Judge issued a Report and Recommendation (“Report”) recommending that Respondent’s motion for summary judgment be granted. [Doc. 22.] The Magistrate Judge advised the parties of the procedures and requirements for filing objections to the Report and the serious consequences if they failed to do so. [Doc. 22-1.] Petitioner filed objections to the Report on January 22, 2024, and Respondent filed a reply to the objections on February 5, 2024.1 [Docs. 26; 29.]

1 The case was reassigned to the undersigned on February 16, 2024. [Doc. 30.] STANDARD OF REVIEW The Magistrate Judge makes only a recommendation to this Court. The recommendation has no presumptive weight, and the responsibility to make a final determination remains with the Court. See Mathews v. Weber, 423 U.S. 261, 270–71 (1976). The Court is charged with making a de novo determination of any portion of the

Report of the Magistrate Judge to which a specific objection is made. The Court may accept, reject, or modify, in whole or in part, the recommendation made by the Magistrate Judge or recommit the matter to the Magistrate Judge with instructions. See 28 U.S.C. § 636(b). The Court will review the Report only for clear error in the absence of an objection. See Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310, 315 (4th Cir. 2005) (stating that “in the absence of a timely filed objection, a district court need not conduct a de novo review, but instead must only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation” (internal quotation marks omitted)).

APPLICABLE LAW Federal courts may not grant habeas corpus relief on any claim that was adjudicated on the merits in state court unless the underlying state adjudication “resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States” or “resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” 28 U.S.C. § 2254(d). “[A] federal habeas court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly. Rather, that application must also be unreasonable.” Williams v. Taylor, 529 U.S. 362, 411 (2000). “A state court’s determination that a claim lacks merit precludes federal habeas relief so long as ‘fairminded jurists could disagree’ on the correctness of the state court’s decision,” and “even a strong case for relief does not mean the state court’s contrary conclusion was

unreasonable.” Harrington v. Richter, 562 U.S. 86, 101–02 (2011). Moreover, state court factual determinations are presumed to be correct, and the petitioner has the burden of rebutting this presumption by clear and convincing evidence. 28 U.S.C. § 2254(e)(1). DISCUSSION

In her habeas petition, Petitioner raises six grounds for relief, which the Court quotes substantially verbatim: GROUND ONE: Ineffective assistance of counsel for trial counsel’s failure to object to the charge of inferred malice.

GROUND TWO: Ineffective assistance of counsel for trial counsel’s failure to object to “seek the truth” language directed to the jury.

GROUND THREE: The South Carolina Supreme Court erred in determining Petitioner did not invoke her right to counsel prior to giving a statement to law enforcement in this case.

GROUND FOUR: The South Carolina Court of Appeals erred in determining the trial court was not required to instruct the jury on self-defense in Petitioner’s trial.

GROUND FIVE: The South Carolina Court of Appeals erred in determining the trial court was not required to instruct the jury on involuntary manslaughter in Petitioner’s trial.

GROUND SIX: Trial counsel was ineffective for allowing the judge to block his questioning related to the Petitioner’s intent at the time of the shooting.

[Doc. 1 at 4–9.] The Court addresses these grounds seriatim. Ground One In analyzing Petitioner’s claim that her trial counsel was ineffective for failing to object to the charge of inferred malice from the use of a weapon, the Magistrate Judge considered the test in Strickland v. Washington, 466 U.S. 668 (1984), and the standard under § 2254(d)2 and concluded that “the PCR court correctly applied the Strickland

standard to this claim and found no prejudice.” [Doc. 22 at 12–18]; see Strickland, 466 U.S. at 687 (establishing that to challenge a conviction based on ineffective assistance of counsel, a prisoner must prove two elements: (1) his counsel was deficient in his representation and (2) he was prejudiced as a result). The Magistrate Judge specifically found that “the PCR court was reasonable in finding that due to the significant evidence of malice other than [Petitioner’s] use of [a] deadly weapon, there was no reasonable probability the erroneous jury instruction contributed to the guilty verdict. Thus, Petitioner failed to meet her burden of proving prejudice by Counsel’s failure to object to it.” [Doc. 22 at 18.]

In her objections, Petitioner contends that the finding that the failure to object did not prejudice Petitioner is “an unreasonable determination of the facts in this case” and that “[t]he trial testimony directly refutes this finding.” [Doc. 26 at 1–2.] Petitioner argues that testimony at trial indicated she was not the primary aggressor at the time of the

2 This Court’s review of a state court’s adjudication of the merits of an ineffective assistance of counsel claim is “doubly deferential”—highly deferential to counsel under Strickland and highly deferential to state courts under 28 U.S.C. § 2254(d). Knowles v. Mirzayance, 556 U.S. 111, 123 (2009). Thus, “[w]hen § 2254(d) applies, the question is not whether counsel’s actions were reasonable” but instead “whether there is any reasonable argument that counsel satisfied Strickland’s deferential standard.” Richter, 562 U.S. at 105.

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Johnson v. Gadson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-v-gadson-scd-2025.