Johnson v. Galloway

CourtDistrict Court, S.D. Illinois
DecidedSeptember 16, 2025
Docket3:22-cv-02072
StatusUnknown

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

Bluebook
Johnson v. Galloway, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS TODD L. JOHNSON, ) ) Petitioner, ) ) vs. ) Case No. 3:22-cv-2072-DWD ) WARDEN GALLOWAY, ) ) Respondent. ) MEMORANDUM & ORDER DUGAN, District Judge: Petitioner, an inmate at Illinois River Correctional Center, filed a Petition for a Writ of Habeas Corpus under 28 U.S.C. § 2254. (Doc. 1). The Court stayed the case because the Petition presented both exhausted and unexhausted claims. (Doc. 7). Thereafter, Petitioner informed the Court, via a Status Report, that his Petition for Leave to Appeal to the Supreme Court of Illinois was denied. (Doc. 8). Therefore, the Court lifted the stay of the case and conducted a preliminary review of the Petition under Rule 4 of the Rules Governing Section 2254 Cases in the U.S. District Courts. The Court ultimately found, based on the limited record available and without commenting on the merits, that the Petition survived a preliminary review. For the reasons explained below, however, the Petition is DENIED on the merits and the action is DISMISSED with prejudice. I. BACKGROUND In June 2016, a jury in the Circuit Court of Peoria County, Illinois, convicted Petitioner of armed robbery and aggravated robbery. (Doc. 1, pg. 1). In October 2016, Petitioner was sentenced to 33 years of imprisonment. (Doc. 1, pg. 1). Petitioner appealed to the Illinois Appellate Court, Third District, raising the following issues: (1) whether defense counsel rendered ineffective assistance of counsel due to the failure to test a gun

for DNA; (2) whether the Illinois trial court erred by failing to consider Petitioner’s request for DNA testing; (3) whether the Illinois trial court committed plain error by conducting a portion of voir dire in chambers without Petitioner; (4) whether the Illinois trial court applied an erroneous procedure when considering Petitioner’s claim under Batson v. Kentucky, 476 U.S. 79 (1986); (5) whether the Illinois trial court erred in striking Petitioner’s motion to quash arrest; and (6) whether the jury’s guilty verdicts were legally

inconsistent. See People v. Johnson, 2020 IL App (3d) 160675, ¶¶ 1, 31; (Doc. 1, pg. 2). When resolving that appeal, the Illinois Appellate Court, over the dissent of one justice, vacated Petitioner’s conviction and remanded the case for a new trial. See Johnson, 2020 IL App (3d) 160675, ¶¶ 47-48; (Doc. 1, pg. 2). In doing so, the Illinois Appellate Court relied on only the first issue raised by Petitioner, i.e., whether defense counsel rendered

ineffective assistance of counsel due to the failure to test a gun for DNA. See Johnson, 2020 IL App (3d) 160675, ¶¶ 32-42. By virtue of its holding on that issue, the Illinois Appellate Court found it unnecessary to consider Petitioner’s five other issues. See id. ¶¶ 44-45. The State of Illinois appealed to the Supreme Court of Illinois, which unanimously reversed the Illinois Appellate Court’s decision and affirmed Petitioner’s conviction in

the Circuit Court of Peoria County. See People v. Johnson, 2021 IL 126291, ¶¶ 1, 52-60; (Doc. 1, pg. 3). The Supreme Court of Illinois remanded the case to the Illinois Appellate Court. On remand, the Illinois Appellate Court considered Petitioner’s five other issues, which were mooted by the holding of its prior decision. See Johnson, 2022 WL App (3d) 160675-UB at ¶¶ 1, 30-57. The Illinois Appellate Court held: (1) the Illinois trial court did not err by failing to consider Petitioner’s request for DNA testing; (2) the Illinois trial

court did not commit plain error by questioning a prospective juror in the absence of Petitioner; (3) the Illinois trial court applied the correct procedure for a Batson challenge; (4) the Illinois trial court properly struck petitioner’s motion to quash arrest; and (5) the verdicts were not legally inconsistent. See Johnson, 2022 IL App (3d) 160675-U, ¶ 1. Petitioner filed his Petition on September 2, 2022, raising the same six grounds for relief. (Doc. 1, generally). However, Petitioner indicated a Petition for Leave to Appeal

was still pending before the Supreme Court of Illinois. (Doc. 1, pg. 7). The Court stayed the case until the Supreme Court of Illinois could resolve that Petition. (Doc. 7). Petitioner later informed the Court that the Supreme Court of Illinois denied his Petition for Leave to Appeal. (Doc. 8, pg. 8). Accordingly, the Court completed a preliminary review under Rule 4. (Doc. 11). The Court, in part, stated: “[I]t appears Petitioner has exhausted his

remedies in the State of Illinois.” (Doc. 11) (citing 28 U.S.C. § 2254(b)(1)(A), (c); Lewis v. Sternes, 390 F.3d 1019, 1025-26 (7th Cir. 2004); U.S. ex rel. Jones v. Uchtman, 387 F. Supp. 2d 856, 863-64 (N.D. Ill. 2005)). It also did not “plainly appear[]” Petitioner was entitled to no habeas relief. (Doc. 11). Based on the limited record available and without commenting on the merits, the Court ordered the service of process on Respondent. (Doc. 11).

II. ANALYSIS The Court’s authority to grant habeas relief to a person in state custody is derived from 28 U.S.C. § 2254, as amended by the Antiterrorism and Effective Death Penalty Act of 1996. Harrington v. Richter, 562 U.S. 86, 97 (2011). Under § 2254, the Court shall entertain a petition for a writ of habeas corpus on behalf of a person in custody pursuant to a state- court judgment only on the ground that he or she is in custody in violation of the

Constitution or the laws or treaties of the United States. 28 U.S.C. § 2254(a). A petition for a writ of habeas corpus shall not be granted with respect to any claim, adjudicated on the merits, unless the adjudication: (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established federal law, as determined by the Supreme Court; or (2) resulted in a decision based on an unreasonable determination of the facts in light of the evidence presented in the state court proceedings. Id. § 2254(d).

A decision is “contrary to…clearly established federal law” if the rule applied differs from the law set forth by the Supreme Court. Bailey v. Lemke, 735 F.3d 945, 949 (7th Cir. 2013) (citing Bell v. Cone, 535 U.S. 685, 694 (2002)). A decision “involve[s] an unreasonable application of clearly established federal law” if the decision correctly identifies, but unreasonably applies, the rule of law to the facts of the case. Id. (citing

Williams v. Taylor, 529 U.S. 362, 407 (2000)). The “operative decision” to be reviewed is that of the last state court to reach the merits of the claim. Stechauner v. Smith, 852 F.3d 708, 714 (7th Cir. 2017) (quoting Harris v. Thompson, 698 F.3d 609, 623 (7th Cir. 2012)). State court determinations of factual issues are presumptively correct, and only clear and convincing evidence will rebut that presumption. 28 U.S.C. § 2254(e)(1).

A state court’s finding that a claim is meritless precludes federal habeas corpus relief under § 2254(d) if “fairminded jurists” could disagree about whether the decision was correct. Harrington, 562 U.S. at 101 (quoting Yarborough v. Alvarado, 541 U.S. 652, 664 (2004)).

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Bluebook (online)
Johnson v. Galloway, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-v-galloway-ilsd-2025.