Kaballah v. Krow

CourtDistrict Court, E.D. Kentucky
DecidedJuly 2, 2024
Docket0:21-cv-00082
StatusUnknown

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

Bluebook
Kaballah v. Krow, (E.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION ASHLAND CONRAI ANDRE KABALLAH, JR. )

) Plaintiff, )

) Civil No. 0:21-cv-00082-GFVT-HAI v. )

) IVAN KROW, Warden, ) ORDER ) Defendant. ) ) *** *** *** *** This matter is before the Court on Plaintiff Conrai Andre Kaballah, Jr.’s Objections [R. 29] to a Report and Recommendation prepared by United States Magistrate Judge Hanly Ingram. [R. 24.] Judge Ingram recommends that the Court deny Mr. Kaballah’s writ of habeas corpus and that no Certificate of Appealability issue. Id. Mr. Kaballah objects to Judge Ingram’s recommended disposition. [R. 29.] For the reasons that follow, Mr. Kaballah’s objections [R. 29] are OVERRULED, Judge Ingram’s Report and Recommendation [R. 24] is ADOPTED as and for the opinion of the Court, and Mr. Kaballah’s Section 2254 petition [R. 1] is DISMISSED with prejudice. I Conrai Kaballah, Jr. is a prisoner of the Commonwealth of Kentucky serving a term of life imprisonment for the attempted murder of another inmate housed at the Louisville Metro Detention Center in 2014. [R. 1; R. 24.] The Kentucky Supreme Court upheld his conviction on August 20, 2020. [R. 1 at 2.]. Mr. Kaballah filed a Section 2254 habeas petition in this Court on November 29, 2021. Id. Mr. Kaballah’s petition asserts that the trial court abused its discretion or otherwise erred in multiple ways, and that the government violated Mr. Kaballah’s constitutional rights. Id. at 2-13. Judge Ingram disagreed and prepared the instant Report and Recommendation. [R. 24.] Therein, he recommends that the Court dismiss Mr. Kaballah’s petition and decline to issue a

certificate of appealability. Id. at 21. Mr. Kaballah objects to Judge Ingram’s Recommendation, and the matter is now ripe for review. [R. 29.] II To receive review of a magistrate judge’s decision, a party must submit particularized objections to a report and recommendation within fourteen days of the date of service thereof. United States v. Campbell, 261 F.3d 628, 632 (6th Cir. 2001); Thomas v. Arn, 728 F.2d 813, 815 (6th Cir. 1984). General objections or objections that require a judge’s interpretation are insufficient to preserve issues. Cowherd v. Million, 380 F.3d 909, 912 (6th Cir. 2004); Miller v. Currie, 50 F.3d 373, 380 (6th Cir. 1995). An objecting party must provide sufficient specificity “to enable the district court to discern those issues that are dispositive and contentious.” Miller,

50 F.3d at 380. Mr. Kaballah objects to Judge Ingram’s recommendation that a certificate of appealability be denied, arguing under Slack v. McDaniel, 529 U.S. 473, 484 (2000) that reasonable jurists would find Judge Ingram’s assessment of the constitutional claims debatable or wrong. [R. 29 at 2.] Mr. Kaballah contends that Judge Ingram’s recommendation is an “unreasonable application of United States Supreme Court case law . . .” as it relates to what Mr. Kaballah believes were violations of his Fifth, Sixth, and Fourteenth Amendment rights at trial. Id. at 3. More specifically, Mr. Kaballah reasserts that several Brady violations occurred at trial, and that a Miranda violation was not harmless error. Id. at 3-7. The Court considers Mr. Kaballah’s objection in turn. B Mr. Kaballah first objects to Judge Ingram’s recommendation that the Court conclude no

Brady violations occurred. Judge Ingram found that no Brady violation occurred where evidence of witness Luke Payne’s sentence reduction was allegedly withheld by the prosecution. Judge Ingram also found that no Brady violation occurred where the Commonwealth did not disclose an alleged threatening phone call from Ricardo Taylor to Payne. And lastly, Judge Ingram found that no Brady violation occurred where the Commonwealth deferred disclosure of Payne’s identity. Mr. Kaballah’s Brady objection argues that the factual predicate upon which the Kentucky Supreme Court and Judge Ingram rely is mistaken. He asserts that Payne’s sentence reduction was not actually revealed until after the close of all proof. [R. 29 at 3.] Mr. Kaballah contends that a Brady violation occurred because the Sixth Amendment’s Confrontation Clause

permits a defendant to cross-examine a witness on the issue of bias. Id. at 4 (citing Davis v. Alaska, 415 U.S. 308, 319-20 (1974)). Mr. Kaballah’s states that “[b]ecause the reduction in Payne’s sentence happened after the close of proof, [Kaballah’s] counsel was not able to accurately cross-examine on the extent to which Payne’s sentence had been reduced and why.” Id. Despite Mr. Kaballah’s objection on this point, Judge Ingram actually addresses Mr. Kaballah’s version of the facts in his Report and Recommendation. Judge Ingram found that “the evidence of Payne’s sentence reduction was provided during trial and was not withheld until ‘after trial.’” [R. 24 at 12.] Judge Ingram acknowledges that the Payne’s sentence reduction was not disclosed until after Payne had testified, but cites Mr. Kaballah’s failure to provide “any Supreme Court case supporting his claim of a Brady violation for evidence that was disclosed during trial, but following the testimony of a witness.” Id. As Judge Ingram correctly pointed out, “Brady generally does not apply to delayed disclosure of exculpatory information, but only

to complete failure to disclose.” Id. at 11 (citing O’Hara v. Brigano, 499 F.3d 492, 502 (6th Cir. 2007) (quoting United States v. Bencs, 28 F.3d 555, 560 (6th Cir. 1994))). Judge Ingram thoroughly examined the Kentucky Supreme Court’s finding that no Brady violation occurred. [R. 24 at 9-11.] He found that Mr. Kaballah’s argument that the very existence of a deal between Payne and the Commonwealth was speculative in nature, and does not “amount to the clear and convincing evidence required to rebut the state court’s factual findings.” Id. Ultimately, Judge Ingram concluded that Mr. Kaballah has failed to show that the Kentucky Supreme Court’s decision was not an unreasonable determination of the facts presented to the trial court. Id. at 10. Because Mr. Kaballah has not provided any Supreme Court case supporting his claim of a Brady violation for evidence that was disclosed during trial,

but following the testimony of a witness, Judge Ingram found that the Kentucky Supreme Court did not unreasonably apply clearly established precedent of the United States Supreme Court. The Court agrees with Judge Ingram’s reasoning. A Brady question in the habeus context is, essentially, about the fairness of the trial and whether prejudice ensued because of the delay in disclosure. Chinn v. Warden, Chillicothe Corr. Inst., 24 F.4th 1096, 1103 (6th Cir. 2022); see also United States v. Paulus, 952 F.3d 717, 728 (6th Cir. 2020). The Court’s duty is not to “ask whether the new evidence creates a reasonable probability of a different result.” Chinn, 24 F.4th at 1103 (quotations omitted). Rather, the Court asks whether any fair minded judge could agree with the state court’s Brady assessment. Id.

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Related

Davis v. Alaska
415 U.S. 308 (Supreme Court, 1974)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Kathy Thomas v. Dorothy Arn
728 F.2d 813 (Sixth Circuit, 1984)
United States v. Ronald Bencs
28 F.3d 555 (Sixth Circuit, 1994)
Miller v. Currie
50 F.3d 373 (Sixth Circuit, 1995)
United States v. Jesse Campbell
261 F.3d 628 (Sixth Circuit, 2001)
Johnny Cowherd v. George Million, Warden
380 F.3d 909 (Sixth Circuit, 2004)
O'HARA v. Brigano
499 F.3d 492 (Sixth Circuit, 2007)
Andrew Davis v. Wayne Carpenter
798 F.3d 468 (Sixth Circuit, 2015)
United States v. Richard E. Paulus
952 F.3d 717 (Sixth Circuit, 2020)
Freddie McNeill, Jr. v. Margaret Bagley
10 F.4th 588 (Sixth Circuit, 2021)
Davel Chinn v. Warden, Chillicothe Corr. Inst.
24 F.4th 1096 (Sixth Circuit, 2022)
Marvin Nicholson v. United States
78 F.4th 870 (Sixth Circuit, 2023)

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Bluebook (online)
Kaballah v. Krow, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kaballah-v-krow-kyed-2024.