KELLAM v. SMITH

CourtDistrict Court, E.D. Pennsylvania
DecidedSeptember 1, 2022
Docket2:19-cv-04271
StatusUnknown

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

Bluebook
KELLAM v. SMITH, (E.D. Pa. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

KAREEM KELLAM, Petitioner, v. CIVIL ACTION NO. 19-4271 BARRY SMITH, et al., Respondents.

ORDER Petitioner Kareem Kellam has filed a habeas petition pursuant to 28 U.S.C. § 2254, challenging his 2007 Pennsylvania conviction for second degree murder, robbery, and criminal conspiracy. Kellam asserts three claims for relief: (1) violation of his Fifth, Sixth, and Fourteenth Amendment rights due to the trial court’s alleged error in permitting Wayne Holland, Kellam’s former cellmate, to testify;1 (2) “violation of his Fifth Amendment rights due to the trial court’s error in refusing to issue a cautionary instruction as requested after the prosecution in its closing statement allegedly commented on Petitioner’s choice not to testify”;2 and (3) violation of his Fifth, Sixth, and Fourteenth Amendment rights due to ineffective assistance of counsel.3 The Petition also alleges violations of Article 1, Sections 1 and 9 of the Pennsylvania Constitution alongside each of Kellam’s federal claims.4 Magistrate Judge Lynne A. Sitarski has issued a

1 Habeas Pet. [Doc. No. 1] at ECF pages 10–11. 2 R&R [Doc. No. 34] at 4; see also Habeas Pet. [Doc. No. 1] at ECF pages 13–14. 3 Habeas Pet. [Doc. No. 1] at ECF pages 16–19. 4 See Habeas Pet. [Doc. No. 1] at ECF pages 10, 13, 16. Report and Recommendation (“R&R”) recommending the denial of Kellam’s petition.5 Kellam has not filed objections to the R&R. As an initial matter, the Court notes that Kellam’s claims under the Pennsylvania Constitution are not explicitly addressed by the R&R. The Court’s limited jurisdiction under 28 U.S.C. § 2254 “extends only to assertions that federal law has been violated.”6 The Court cannot

review a state court’s adjudication of rights under state law, and the R&R correctly excludes those claims from discussion. To the extent that these pleadings represent independent claims, Kellam’s claims under state law are dismissed for lack of jurisdiction. The R&R concludes, and the Court agrees, that the federal claims Kellam asserts in Claims One and Two were not presented to the Pennsylvania courts. As a general matter, a prisoner seeking to challenge their state conviction in federal court under 28 U.S.C. § 2254 must have “exhausted the remedies available” in Pennsylvania’s courts.7 Although Kellam complained of the same conduct underlying these claims on state law grounds, under § 2254 “a claim is not ‘fairly presented’ if the state court ‘must read beyond a petition or a brief . . . in order to find material’ that indicates the presence of a federal claim.”8 Kellam presents no other grounds for

this Court to waive this exhaustion requirement, and the Court adopts the R&R’s conclusion that Claims One and Two are now procedurally defaulted.9

5 R&R [Doc. No. 34]. 6 Gaines v. Superintendent Benner Twp. SCI, 33 F.4th 705, 713 (3d Cir. 2022). 7 28 U.S.C. § 2254(b)(1)(A). 8 Collins v. Sec’y of Pa. Dep’t of Corr., 742 F.3d 528, 542 (3d Cir. 2014) (alteration in original) (quoting Baldwin v. Reese, 541 U.S. 27, 32 (2004)). 9 See R&R [Doc. No. 34]at 9–16. 2 Claim Three, ineffective assistance of counsel, is broken into subparts (i)–(iv). In his Petition, Kellam concedes that Claim Three subparts (i), (ii), and (iv) were not exhausted due to amendments by his PCRA counsel and argues that this should be excused because “he is actually innocent of the crimes for which he was convicted and . . . it was a miscarriage of justice” for PCRA counsel not to assert these claims.10

“[T]here is a narrow class of cases in which, in order to avoid a fundamental miscarriage of justice, evidence of a petitioner’s actual innocence” permits courts to ignore procedural barriers to relief like exhaustion.11 However, “a petitioner must present new, reliable evidence” of his actual innocence “that was not presented at trial” in order for a court to ignore a failure to exhaust state remedies.12 “As part of the reliability assessment of the first step, the court ‘may consider how . . . the likely credibility of the witnesses bear on the probable reliability of that evidence,’ as well as the circumstances surrounding the evidence and any supporting corroboration.”13 Kellam alleges that the testimony of McCandless would rebut the testimony of one of the

Commonwealth’s witnesses, McCandless’s then-boyfriend Robert White. Specifically, McCandless would allegedly testify that White, the owner of the gun with which the murder was committed, told her a different version of the robbery and murder for which Kellam was convicted.14

10 Habeas Pet. [Doc. No. 1] at ECF pages 16, 19. 11 Houck v. Stickman, 625 F.3d 88, 93 (3d Cir. 2010). 12 Id. (citation omitted). 13 Reeves v. Fayette SCI, 897 F.3d 154, 161 (3d Cir. 2018) (quoting House v. Bell, 547 U.S. 518, 537, 551 (2006)) (cleaned up), as amended (July 25, 2018). 14 Habeas Pet. [Doc. No. 1] at ECF page 17. 3 The Court agrees with the R&R’s conclusion that McCandless’s purported testimony does not meet the standard for new and reliable evidence. McCandless was not an eyewitness; Kellam only claims that McCandless would testify that the version of events which White told her did not place Kellam at the scene of the robbery and murder for which he and his co- defendants were convicted.15 Further, McCandless was actually present at Kellam’s trial as a

potential witness for both the prosecution and defense. However, neither side called her; as the prosecution explained on the record, without contradiction from Kellam’s attorney, McCandless did not recall her earlier statements and had a pattern of active drug use that led counsel to believe she would be an unreliable witness.16 On the record before this Court, Kellam has not established that McCandless’s testimony makes this the “rare and extraordinary case where a petition presents evidence of innocence so strong that a court cannot have confidence in the outcome of the trial unless the court is also satisfied that the trial was free of nonharmless constitutional error.”17 The Court adopts the R&R’s conclusion that Kellam’s Claim Three, sub- claims (i), (ii), and (iv) “are procedurally defaulted and his actual innocence argument fails” to cure this default.18

Claim Three subpart (iii) was presented in Kellam’s state court proceedings, and is ripe for review on the merits. This claim alleges that Kellam’s “[t]rial counsel rendered ineffective assistance . . . for failing to seek a curative instruction or mistrial following the prosecution’s opening statements related to what the prosecution asserts would have been the testimony of a

15 Habeas Pet. [Doc. No. 1] at ECF page 17. 16 See Res. [Doc. No. 17] at 17. 17 Reeves, 897 F.3d at 161 (internal quotation marks and citation omitted). 18 R&R [Doc. No. 34] at 18.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Baldwin v. Reese
541 U.S. 27 (Supreme Court, 2004)
House v. Bell
547 U.S. 518 (Supreme Court, 2006)
Houck v. Stickman
625 F.3d 88 (Third Circuit, 2010)
Commonwealth v. Brown
711 A.2d 444 (Supreme Court of Pennsylvania, 1998)
Jerry Reeves v. Superintendent Fayette SCI
897 F.3d 154 (Third Circuit, 2018)
Lawrence Gaines v. Superintendent Benner Township
33 F.4th 705 (Third Circuit, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
KELLAM v. SMITH, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kellam-v-smith-paed-2022.