King v. Garrett

CourtDistrict Court, D. Nevada
DecidedSeptember 23, 2025
Docket3:18-cv-00202
StatusUnknown

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

Bluebook
King v. Garrett, (D. Nev. 2025).

Opinion

3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 * * *

6 ALEXANDER STEVEN KING, Case No. 3:18-cv-00202-MMD-WGC

7 Petitioner, ORDER v. 8 TIM GARRETT, et al., 9 Respondents. 10

11 I. SUMMARY 12 Petitioner Alexander Steven King, a Nevada state prisoner, filed a Second 13 Amended Petition for Writ of Habeas Corpus under 28 U.S.C. § 2254 (ECF No. 56 14 (“Second Amended Petition”)). This matter is before the Court for adjudication on the 15 merits of the Second Amended Petition. The Court denies the Second Amended Petition 16 and denies a Certificate of Appealability (“COA”). 17 II. BACKGROUND 18 A. Facts Underlying Conviction 19 On January 3, 2011, King was committing a residential burglary in Silver Springs, 20 Nevada, when the residents, Stuart Gardner and his girlfriend, returned home 21 unexpectedly. (ECF No. 26-3 at 7.) Gardner’s girlfriend caught King in their bedroom. (Id.) 22 King shoved Gardner’s girlfriend out of the doorway and ran out of the house. (Id.) 23 Gardner’s girlfriend yelled for Gardner, and Gardner attempted to stop King. (Id.) King 24 pulled out a gun and shot Gardner in the chest. (Id.) 25 B. Procedural Background 26 The state court entered a judgment of conviction upon a guilty plea of first-degree 27 murder (i.e., felony murder) with use of a deadly weapon. (ECF No. 22-20.) The state 28 court sentenced King to a maximum term of life in prison with parole eligibility after 20 2 The Nevada Court of Appeals affirmed the judgment of conviction. (ECF No. 22-25.) 3 King filed a pro se state petition seeking postconviction relief. (ECF No. 22-27.) 4 Following an evidentiary hearing, the state court denied the state petition. (ECF Nos. 23- 5 1, 23-2.) The Nevada Court of Appeals affirmed the state court’s denial of relief. (ECF 6 No. 23-7.) 7 King initiated this federal habeas proceeding pro se. (ECF No. 1.) Following 8 appointment of counsel, King filed his first amended petition, alleging three grounds for 9 relief. (ECF Nos. 7, 20.) The Court granted Respondents’ motion to dismiss in part finding 10 Grounds 1(A) and 2 exhausted and finding Grounds 1(C) and 3 unexhausted. (ECF No. 11 46.) The Court granted King’s motion for stay and abeyance to return to state court and 12 exhaust his unexhausted claims. (ECF No. 49.) 13 In August 2020, King filed his second state petition seeking postconviction relief. 14 (ECF No. 57-1.) The state court denied the petition on procedural grounds as successive 15 and untimely. (ECF No. 57-2.) The Nevada Supreme Court affirmed on appeal. (ECF No. 16 57-4.) In June 2022, the Court reopened this federal habeas proceeding, and King filed 17 his Second Amended Petition. (ECF No. 56.) The Court granted Respondents’ motion to 18 dismiss in part. (ECF No. 72.) 19 III. LEGAL STANDARD 20 A. Review Under the Antiterrorism and Effective Death Penalty Act

21 28 U.S.C. § 2254(d) sets forth the standard of review generally applicable in 22 habeas corpus cases under the Antiterrorism and Effective Death Penalty Act (AEDPA): 23 An application for a writ of habeas corpus on behalf of a person in custody pursuant to the judgment of a State court shall not be granted with respect 24 to any claim that was adjudicated on the merits in State court proceedings unless the adjudication of the claim – 25

26 (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the 27 Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination 28 of the facts in light of the evidence presented in the State court proceeding. 2 precedent, within the meaning of § 2254(d)(1), “if the state court applies a rule that 3 contradicts the governing law set forth in [Supreme Court] cases” or “if the state court 4 confronts a set of facts that are materially indistinguishable from a decision of [the 5 Supreme] Court.” Lockyer v. Andrade, 538 U.S. 63, 73 (2003) (quoting Williams v. Taylor, 6 529 U.S. 362, 405-06 (2000); and citing Bell v. Cone, 535 U.S. 685, 694 (2002)). A state 7 court decision is an unreasonable application of established Supreme Court precedent 8 under § 2254(d)(1) “if the state court identifies the correct governing legal principle from 9 [the Supreme] Court’s decisions but unreasonably applies that principle to the facts of the 10 prisoner’s case.” Id. at 75 (quoting Williams, 529 U.S. at 413). “The ‘unreasonable 11 application’ clause requires the state court decision to be more than incorrect or 12 erroneous. The state court’s application of clearly established law must be objectively 13 unreasonable.” Id. (internal citation omitted) (quoting Williams, 529 U.S. at 409-10). 14 The Supreme Court has instructed that a “state court’s determination that a claim 15 lacks merit precludes federal habeas relief so long as ‘fairminded jurists could disagree’ 16 on the correctness of the state court’s decision.” Harrington v. Richter, 562 U.S. 86, 101 17 (2011) (quoting Yarborough v. Alvarado, 541 U.S. 652, 664 (2004)). The Court has stated 18 that “even a strong case for relief does not mean the state court’s contrary conclusion 19 was unreasonable.” Id. at 102 (citing Lockyer, 538 U.S. at 75); see also Cullen v. 20 Pinholster, 563 U.S. 170, 181 (2011) (internal quotation marks and citations omitted) 21 (describing the standard as “difficult to meet” and “highly deferential standard for 22 evaluating state court rulings, which demands that state court decisions be given the 23 benefit of the doubt”). 24 B. Standard For Ineffective Assistance of Counsel Claims 25 In Strickland v. Washington, the Supreme Court propounded a two-prong test for 26 analysis of claims of ineffective assistance of counsel requiring Petitioner to demonstrate 27 that: (1) the attorney’s “representation fell below an objective standard of 28 reasonableness[;]” and (2) the attorney’s deficient performance prejudiced Petitioner 2 the result of the proceeding would have been different.” 466 U.S. 668, 688, 694 (1984). 3 Courts considering an ineffective assistance of counsel claim must apply a “strong 4 presumption that counsel’s conduct falls within the wide range of reasonable professional 5 assistance.” Id. at 689. It is Petitioner’s burden to show “counsel made errors so serious 6 that counsel was not functioning as the ‘counsel’ guaranteed . . . by the Sixth 7 Amendment.” Id. at 687. Additionally, to establish prejudice under Strickland, it is not 8 enough for Petitioner “to show that the errors had some conceivable effect on the outcome 9 of the proceeding.” Id. at 693. Rather, the errors must be “so serious as to deprive the 10 [petitioner] of a fair trial, a trial whose result is reliable.” Id. at 687. 11 Where a state district court previously adjudicated the claim of ineffective 12 assistance of counsel under Strickland, establishing the decision was unreasonable is 13 especially difficult. See Richter, 562 U.S. at 104-05. In Richter, the Supreme Court 14 clarified that Strickland and § 2254(d) are each highly deferential, and when the two apply 15 in tandem, review is doubly so. See id. at 105; see also Cheney v. Washington, 614 F.3d 16 987, 995 (9th Cir.

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King v. Garrett, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-garrett-nvd-2025.