King v. Secretary, Department of Corrections (Pinellas)

CourtDistrict Court, M.D. Florida
DecidedFebruary 11, 2025
Docket8:22-cv-00659
StatusUnknown

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

Bluebook
King v. Secretary, Department of Corrections (Pinellas), (M.D. Fla. 2025).

Opinion

UMNIIDTEDDL ES TDAISTTERS IDCITS TORFI FCLTO CROIDURAT TAMPA DIVISION

CURTIS KING,

Applicant,

v. CASE NO. 8:22-cv-659-SDM-SPF

SECRETARY, Department of Corrections,

Respondent. ____________________________________/

ORDER

King applies (Doc. 1) under 28 U.S.C. § 2254 for the writ of habeas corpus and challenges his conviction for lewd and lascivious molestation, for which King is imprisoned for life. Numerous exhibits (“Respondent’s Exhibit”) support the response. (Doc. 8) The respondent (1) argues that some grounds are not fully exhausted and, consequently, are procedurally barred from federal review and (2) admits the application’s timeliness. (Response at 8, Doc. 3) I. BACKGROUND1 King was living with his girlfriend and her two children. One evening before going to her midnight shift the girlfriend awakened to find that King was not in bed. Upon entering the family room the girlfriend saw King attempting to masturbate her

1 This summary of the facts derives from King’s brief on direct appeal. (Respondent’s Exhibit 21) four-year-old son. The girlfriend told King to get his property and move out, took her two children to their father’s house, and went to her work. Two days later the girlfriend reported the incident to the police. At the girlfriend’s request, King returned to the house and was interviewed by the police. After waiving his Miranda rights, King confessed to the inappropriate touching.

In his application King alleges four grounds for relief. The first two grounds allege that trial counsel rendered ineffective assistance, and the last two grounds allege that the trial court committed error, which grounds the respondent contends are unexhausted as a federal claim. II. EXHAUSTION AND PROCEDURAL DEFAULT

The respondent argues that Grounds Three and Four are procedurally barred from federal review because King failed to fully exhaust his available state court remedies by not arguing on direct appeal that the alleged trial court error violated a constitutional right. An applicant must present each claim to a state court before presenting the claim to a federal court. “[E]xhaustion of state remedies requires that

petitioners ‘fairly presen[t]’ federal claims to the state courts in order to give the State the ‘opportunity to pass upon and correct’ alleged violations of its prisoners’ federal rights.” Duncan v. Henry, 513 U.S. 364, 365 (1995) (quoting Picard v. Connor, 404 U.S. 270, 275 (1971)). Accord Rose v. Lundy, 455 U.S. 509, 518–19 (1982) (“A rigorously enforced total exhaustion rule will encourage state prisoners to seek full

relief first from the state courts, thus giving those courts the first opportunity to review all claims of constitutional error.”). “To provide the State with the necessary ‘opportunity,’ the prisoner must ‘fairly present’ his claim in each appropriate state court (including a state supreme court with powers of discretionary review), thereby alerting that court to the federal nature of the claim.” Baldwin v. Reese, 541 U.S. 27, 32 (2004) (citing Duncan). Grounds Three and Four:

The respondent correctly argues that King never presented to the state court the federal claims that the trial court erred in both denying his motion to suppress his statement to the police (Ground Three) and refusing a special jury instruction (Ground Four). King identified the substance of Grounds Three and Four as Issues I and IV on direct appeal (Respondent’s Exhibit 21), but he limited

each issue as a violation of state law and not as the violation of a federally protected right. The exhaustion requirement is not met if a defendant fails to alert the state appellate court that the trial court allegedly violated a federally protected right. As Reese explains, 541 U.S. at 32, an applicant must alert the state court that he is raising a federal law claim and not just a state law claim.

A litigant wishing to raise a federal issue can easily indicate the federal law basis for his claim in a state-court petition or brief, for example, by citing in conjunction with the claim the federal source of law on which he relies or a case deciding such a claim on federal grounds, or by simply labeling the claim “federal.”

As a consequence, “[i]t is not enough that all the facts necessary to support the federal claim were before the state courts, or that a somewhat similar state-law claim was made.” Anderson v. Harless, 459 U.S. 4, 6 (1982). See also Kelley v. Sec’y for Dep’t of Corr., 377 F.3d 1271, 1345 (11th Cir. 2004) (“The exhaustion doctrine requires a habeas applicant to do more than scatter some makeshift needles in the haystack of the state court record.”) (citations omitted); Upshaw v. Singletary, 70 F.3d 576, 578 (11th Cir. 1995) (“[T]he applicant must have fairly apprised the highest court of his state with the appropriate jurisdiction of the federal rights which allegedly were violated.”). An applicant must present to the federal court the same claim that was

presented to the state court. Picard v. Connor, 404 U.S. at 275 (“[W]e have required a state prisoner to present the state courts with the same claim he urges upon the federal courts.”). “[M]ere similarity of claims is insufficient to exhaust.” Duncan, 513 U.S. at 366. The failure to properly exhaust each available state court remedy causes a

procedural default of the unexhausted claim. O’Sullivan v. Boerckel, 526 U.S. 838, 848 (1999) (“Boerckel’s failure to present three of his federal habeas claims to the Illinois Supreme Court in a timely fashion has resulted in a procedural default of those claims.”); see also Snowden v. Singletary, 135 F.3d 732, 736 (11th Cir. 1998) (“[W]hen it is obvious that the unexhausted claims would be procedurally barred in state court

due to a state-law procedural default, we can forego the needless ‘judicial ping-pong’ and just treat those claims now barred by state law as no basis for federal habeas relief.”). State procedural rules preclude King from returning to state court to present his federal claim in a second, untimely direct appeal. See Fla. R. App. P. 9.140(b)(3). King’s failure to properly present his federal claim in the state court results in a

procedural default. See Shinn v. Ramirez, 596 U.S. 366, 378 (2022) (noting that if a prisoner failed to present a federal claim to the state court and the state court would dismiss the claim based on a procedural failure, the claim is technically exhausted because, in the habeas context, “state-court remedies are . . . ‘exhausted’ when they are no longer available, regardless of the reason for their unavailability.”) (quoting Woodford v. Ngo, 548 U.S. 81, 92–93 (2006)). King procedurally defaulted Grounds Three and Four by not “federalizing”

each ground in state court, and, as a consequence, each ground is barred from federal review absent a showing of “actual cause and prejudice” or “manifest injustice.” See generally Coleman v. Thompson, 501 U.S. 722, 747–51 (1991); Murray v. Carrier, 477 U.S. 478, 496 (1986). The basis for “cause” must ordinarily reside in something external to the defense. Marek v. Singletary, 62 F.3d 1295, 1302 (11th Cir. 1995). To

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