Joshua Carbaugh v. Warden, Chillicothe Correctional Institution

District Court, S.D. Ohio·Decided July 29, 2026·No. 2:25-cv-01258·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS JOSHUA CARBAUGH, Petitioner, : Case No. 2:25-cv-01258 -vs - District Judge Algenon L. Marbley Magistrate Judge Michael R. Merz WARDEN, Chillicothe Correctional Institution, : Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case, brought pro se by Petitioner Joshua Carbaugh, is before the Court for decision on the Petition (ECF No. 1), the State Court Record (ECF No. 7), and the Return of Writ (ECF No. 8). Chief Magistrate Judge Stephanie Bowman set a reply deadline of twenty-one

days after the Return was filed (Order, ECF No. 5). That deadline was May 7, 2026, because the Return was served by mail. However, that deadline has passed and no reply has been filed. The Magistrate Judge reference in this case was recently transferred to the undersigned to help balance the Magistrate Judge workload in the District.

Litigation History

On January 16, 2020, the Muskingum County Grand Jury returned an indictment charging Carbaugh with one count of rape (victim less than ten years of age) in violation of Ohio Revised Code § 2907.02(A)(1)(b), with a sexually violent predator specification, one count of gross sexual imposition in violation of Ohio Revised Code § 2907.05(A)(4)), and three counts of failure to register as a sex offender in violation of Ohio Revised Code § 2950.04 (Indictment, State Court Record ECF No. 7, Ex. 1). The first two counts were tried to a jury which found Petitioner guilty. The failure to register

counts were tried to the bench and resulted in guilty verdicts. Petitioner was sentenced to an aggregate term of life imprisonment without the possibility of parole plus fourteen years. Represented by new counsel, Petitioner appealed to the Ohio Fifth District Court of Appeals which affirmed. State v. Carbaugh, 2023-Ohio-1269 (Ohio App. 5th Dist. Apr. 18, 2023). The Ohio Supreme Court granted Petitioner’s motion for delayed appeal but then declined to exercise jurisdiction. State v. Carbaugh, 172 Ohio St.3d 1409 (2023). Petitioner filed an Application to Reopen under Ohio R. App. P. 26(B) to litigate issues of ineffective assistance of appellate counsel (State Court Record, ECF No. 7, Ex. 32). The Fifth District denied the Application and the Supreme Court declined to exercise jurisdiction over a

further appeal. State v. Carbaugh, 175 Ohio St. 3d 1531 (2024). Carbaugh filed his Petition in this Court by placing it in the prison mailing system on October 28, 2025. He pleads the following grounds for relief:

Ground One: The proportionality of the sentence was inconsistent with the principles set forth in Ohio Revised Code 2929.11 and the factors to be considered in Ohio Revised Code 2929.12 in violation of Oh Const. Art. 1, 9 and 10 as well as USCS Const. Amends. 1, 4, 6, 8, and 14.

Supporting Facts: The Trial Court stepped outside of the Constitutional norms when it imposed the sentence and sanction that it did. Ground Two: The consecutive sentences on Counts 2, 3, and 5 are contrary to the sentencing statutes in violation of Oh Const. Art. 1, 2, 5, 9, 10, and 16 as well as USCS Const. Amends. 5, 6, 8, and 14.

Supporting Facts: The Trial Court stepped outside of the Constitutional norms when it imposed the sentence and sanction that it did.

Ground Three: Petitioner conviction was against the manifest weight of the evidence in violation of Oh Const. Art. 11, 5, 10, 14, and 16 as well as USCS Const. Amends. 4, 5, 6, and 14.

Supporting Facts: The evidence was against the manifest weight based on credibility of the witnesses.

Ground Four: There was insufficient evidence to sustain a conviction in violation of Oh Const. Art. 1, 1, 5, 10, 14, and 16 as well as USCS Const. Amends. 1, 4, 5, 6, and 14.

Supporting Facts: The elements vs. the evidence does not allow for a constitutional conviction.

Ground Five: The Trial Court erred by admitting State’s exhibit V- 1 which were not statements made for the purpose of medical diagnosis or treatment in violation of Oh. Const. Art. 1 1, 4, 5, 6, 8, and 14.

Supporting Facts: Petitioner’s Due Process Rights were violated by the prejudicial use of false medical statements to implead (sic) on petitioner’s credibility before the jury.

Ground Six: The Trial Court erred by denying Joshua’s motion for mistrial based on prosecutorial misconduct in violation of Oh.Const. Art. 1. 5, 10, and 16, as well as USCS Const. Amends. 1, 4, 5, 6, 8, and 14.

Supporting Facts: The Petitioner’s Rights to a fair trial and Due Process were violated by prosecutorial misconduct infringing on the integrity of the entire trial.

Ground Seven: A tainted jury member poisons the entire proceeding violating the petitioner’s 6th and 14th Amendment Rights guaranteed by the United States Constitution and Ohio's Constitution, Counsel was ineffective during direct appeal for failing to raise this issue. Supporting Facts: The Juror was tainted because she worked on the board of an advocacy center that deals directly with children and was given the job by the prosecuting Attorney who she admitted to being friends with.

Ground Eight: Appellate Attorney’s unprofessional representation violated the Petitioner’s 6th Amendment Right to Effective Appellate Counsel by failing to argue: hearsay violation; failed to request a Daubert Hearing; failed to argue facts about false reporting; failure to raise issue on tainted Juror; failed to request certification on conflict.

Supporting Facts: Appellate Counsel failed to raise grounds that were material to the case.

Ground Nine: Trial Attorney’s unprofessional representation violated the petitioner’s 6th Amendment right to effective Counsel. Counsel was ineffective during Direct Appeal for failing to raise this issue.

Supporting Facts: Trial Counsel was ineffective for not arguing tainted Juror and failing to ask for change of venue. Appellate counsel failed to raise this issue.

(Petition, ECF No. 1, PageID 8-23). Analysis Ground One: Disproportionate Sentence In his First Ground for Relief, Petitioner asserts his sentence violates certain laws governing sentencing: Ohio Revised Code 2929.11 and 2929.12, Articles 1 and 9 of the Ohio Constitution, and Amendments 1, 4, 6, 8, and 14 of the United States Constitution. Federal habeas corpus is available only to correct federal constitutional violations. 28 U.S.C. § 2254(a); Wilson v. Corcoran, 562 U.S. 1 (2010); Lewis v. Jeffers, 497 U.S. 764, 780 (1990); Smith v. Phillips, 455 U.S. 209 (1982), Barclay v. Florida, 463 U.S. 939 (1983). “A petitioner must claim that his custody violates federal law, not state law, not some other source of law.” Bailey v. Wainwright, 951 F.3d 343, 346 (6th Cir. 2020) citing Wilson. "[I]t is not the province of a federal habeas court to reexamine state court determinations on state law questions. In conducting habeas review, a federal court is limited to deciding whether a conviction violated the Constitution, laws, or treaties of the United States." Estelle v. McGuire, 502 U.S. 62, 67-68 (1991); see also Elmendorf v. Taylor, 23 U.S. (10 Wheat.) 152, 160 (1825)(Marshall C. J.);

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Joshua Carbaugh v. Warden, Chillicothe Correctional Institution, (S.D. Ohio 2026).

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