Joseph Leonard v. Patrick Eaton

CourtDistrict Court, E.D. California
DecidedOctober 30, 2025
Docket2:19-cv-00230
StatusUnknown

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

Bluebook
Joseph Leonard v. Patrick Eaton, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 FOR THE EASTERN DISTRICT OF CALIFORNIA 9 10 JOSEPH LEONARD, No. 2:19-cv-0230-TLN-SCR 11 Petitioner, 12 v. FINDINGS & RECOMMENDATIONS 13 PATRICK EATON, 14 Respondent. 15 16 Petitioner is a state prisoner representing himself in this habeas corpus action filed 17 pursuant to 28 U.S.C. § 2254. Petitioner challenges his 2015 conviction from the Sacramento 18 County Superior Court for murder and attempted murder following an altercation in a 19 McDonald’s parking lot. Upon careful consideration of the record and the applicable law, the 20 undersigned recommends denying petitioner’s habeas corpus application on the merits. 21 I. Factual and Procedural History 22 A. Trial Court Proceedings 23 Following a jury trial, petitioner was convicted of first degree murder and premeditated 24 attempted murder. ECF No. 10-1 (Abstract of Judgment). The jury also found true 25 enhancements for personal use of a deadly weapon (i.e., a motor vehicle) and hate crime 26 allegations based on the victims’ ethnicity. ECF No. 50-7 at 118, 121 (Verdict Forms). On 27 January 9, 2015, petitioner was sentenced to an indeterminate state prison term totaling forty 28 years to life. ECF No. 10-1. 1 After independently reviewing the record, this court finds the state appellate court’s 2 summary of the evidence accurate and adopts it herein.1 3 Prosecution’s case-in-chief 4 1. The killing 5 On the morning of June 6, 2013, [petitioner] and Samantha Silva arrived at McDonald’s in [petitioner]’s truck for coffee.2 [Footnote 6 omitted.] After a while, Silva walked outside of the restaurant and noticed two men. One had on a backpack; the other had a bicycle. 7 The men offered her food to eat and asked if she was hungry. She said she was not and continued to the truck. 8 The two men, Toussaint Harrison and Justin Oliphant, were giving 9 away food they had taken from a motel to homeless people at the McDonald’s parking lot. Harrison was on a bike. They asked Silva 10 for money and cigarettes, and offered her some food. She declined their requests and offers. 11 When [petitioner] returned to the truck, Silva, who is mentally 12 disabled, told [petitioner] that Oliphant and Harrison were bothering her. This angered [petitioner], and he told them to leave Silva alone. 13 The three men argued and cursed at each other with racial epithets and insults. 14 [Petitioner] walked back to his truck and retrieved a long chain. He 15 swung it at Oliphant and Harrison. The three men fought, as [petitioner] tried to hit the other two with the chain. One of the men 16 punched [petitioner]. Oliphant pulled out a pocket knife but it fell on the ground. Harrison threw something sharp at [petitioner], possibly 17 a broken bottle or a pocket knife, and it cut his cheek. During the fight, [petitioner] called the two men various racial slurs and 18 derogatory epithets. The altercation lasted about one minute, after which [petitioner] walked back to his truck and Oliphant and 19 Harrison walked toward the McDonald’s entrance. [Footnote omitted.] 20 [Petitioner] backed his truck to the McDonald’s entrance where 21 Oliphant and Harrison were standing. He got out of the truck and chased the two men around the parking lot while swinging the chain. 22 After a minute or so, he walked back to the McDonald’s entrance and stomped on Harrison’s bike. He briefly picked it up, but he dropped 23 it when Oliphant ran toward his truck and threatened to smash the windows. Harrison grabbed his bike, and he and Oliphant walked 24 away and out of the parking lot. [Petitioner], still holding the chain, went inside McDonald’s and gave an employee a pocket knife. He 25

26 1 See 28 U.S.C. § 2254(e)(1) (emphasizing that “a determination of a factual issue made by a State court shall be presumed to be correct” unless the petitioner rebuts it by clear and convincing 27 evidence). 2 The court has replaced “defendant” with “petitioner” to reflect the procedural posture of this 28 habeas corpus proceeding. The changes are indicated in brackets. 1 returned to his truck and left the parking lot. 2 After they left McDonald’s, Oliphant and Harrison went through a parking lot towards an IHOP restaurant. Oliphant walked and 3 Harrison rode his bike. [Petitioner] drove his truck into the parking lot and sped towards them. Oliphant heard a loud “revving” engine 4 and saw [petitioner]’s truck about 20 feet away coming toward them at a high rate of speed. The truck came at Oliphant. He dove out of 5 the way and landed on the parking lot. The truck hit a sign for a car wash. 6 [Petitioner] reversed the truck, turned around, and headed towards 7 Harrison. Oliphant yelled at Harrison to move. [Petitioner] hit Harrison full-force with the front of the truck. Harrison flew into the 8 air and into the truck’s windshield, rolled off the truck, and landed on the ground. After striking Harrison, [petitioner] stopped, reversed 9 the truck, turned around, and started chasing Oliphant. He tried to hit him two additional times, but Oliphant dodged and jumped out of the 10 way to avoid being hit. Oliphant fled the scene on foot. 11 Frank Folger, an employee at Clutch Mart, heard a squealing sound of tires and a thud. Another Clutch Mart employee, Dan Gandy, also 12 heard the noise. He went outside and saw Harrison lying on the ground, bleeding. He yelled at Folger to call 911. Folger called as he 13 walked outside holding a cordless phone. A Black male who identified himself as a relative of the injured man picked up 14 Harrison’s bicycle and left. 15 After Oliphant escaped, [petitioner] turned his truck around and drove back towards Harrison, who was still lying on the ground. 16 Seeing this, Gandy ran and placed himself between the motionless Harrison and [petitioner]’s truck. [Petitioner] kept driving towards 17 Gandy, but when he got within 10 feet of Gandy, he swerved away and stopped. He got out of his truck, approached Harrison, and 18 kicked him in the head and torso numerous times with his steel-toed boots. He yelled racial and derogatory slurs while he kicked 19 Harrison. 20 Folger walked up and yelled at [petitioner] to stay away from Harrison. Gandy ran into his store and retrieved a large pry bar. He 21 came back holding the bar and told [petitioner] to get away from Harrison. When [petitioner] backed away, Gandy took the keys out 22 of the truck’s ignition and told [petitioner] to sit on the tailgate until police arrived. [Petitioner] told Gandy when this was all done, he 23 knew where Gandy worked and they would settle it. 24 Harrison died from blunt force injuries to the head. He also suffered blunt force injuries to his torso, a dislocated and fractured right 25 clavicle, five broken lumbar vertebrae, and blunt force injuries to his arms and legs. His injuries were consistent with being struck by a 26 motor vehicle. The pathologist believed more of Harrison’s injuries were caused by being hit by the truck than by being kicked or 27 stomped. Harrison’s blood tested positive for amphetamine and methamphetamine, but negative for alcohol and other illicit 28 substances. 1 2. [Petitioner]’s arrest 2 Deputies detained [petitioner] at the scene. Asked how the altercation continued so far away from McDonald’s, [petitioner] said the 3 altercation just continued that way. He also said, “If that fucker dies, oh well, he tried to kill me.” 4 [Petitioner] said a number of things over the next two hours while he 5 was detained and recorded in a patrol car. He said, “I was fearin’ for my life. You see what they did to me, man.” He continued, “[T]hey 6 chased me, then . . . I beat ‘em off me, and then next thing I know, you know, I’m over here—we’re over here. I don’t know. It just 7 happened so fast. . . .

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Joseph Leonard v. Patrick Eaton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-leonard-v-patrick-eaton-caed-2025.