Klusty v. Krueger

CourtDistrict Court, S.D. Ohio
DecidedJanuary 14, 2020
Docket2:17-cv-00062
StatusUnknown

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

Bluebook
Klusty v. Krueger, (S.D. Ohio 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

GARY KLUSTY,

Petitioner, : Case No. 2:17-CV-062

- vs - Chief Judge Algenon L. Marbley Magistrate Judge Michael R. Merz

JEFFREY NOBLE, Warden, London Correctional Institution

: Respondent. SUPPLEMENTAL REPORT AND RECOMMENDATIONS

This habeas corpus case is before the Court on Petitioner’s Objections to Magistrate Judge’s Report and Recommendations ( the “Report,” ECF No. 24). Chief Judge Marbley has reopened the judgment and recommitted the case for reconsideration in light of the Objections (ECF No. 22, 25).

General Objection

At the outset of his Objections, Klusty writes that he “objects to each and every finding of fact and conclusion of law in the Report and Recommendations which is adverse to Klusty’s claims for relief.” (Objections, ECF No. 24, PageID 1574.) Only specific objections are preserved for appellate review. Smith v. Detroit Federation of Teachers, 829 F.2d 1370, 1373 (6th Cir. 1987). The district court need not provide de novo review where objections to a magistrate judge's report and recommendations are frivolous, conclusive, or general. Parties have a “duty to pinpoint” portions of the report that the Court should consider. Mira v. Marshall, 806 F.2d 636, 637 (6th Cir. 1986), quoting Nettles v. Wainwright, 677 F.2d 404, 410 (5th Cir. 1982)(internal quotation marks omitted).

Ground One: Pre-Indictment Delay

In his First Ground for Relief, Klusty argued that the delay of his re-indictment1 in this case denied him due process of law. The Ohio Fifth District Court of Appeals decided this claim on the merits. State v. Klusty, 2015-Ohio-2843 (5th Dist. Jul. 13, 2015), appellate jurisdiction

declined, 144 Ohio St. 3d 1459 (2016). Respondent defended this Ground for Relief on the merits. The Report concluded the Fifth District’s thorough analysis was neither contrary to nor an objectively unreasonable application of clearly established Supreme Court precedent, particularly United States v. Lovasco, 431 U.S. 783 (1977)(Report, ECF No. 12, PageID 1515-23).

Klusty objects that the Supreme Court has held “excessive delay presumptively compromises the reliability of a trial,” (Objections, ECF No. 24, quoting Doggett v. United States, 505 U.S. 647, 655 (1992)). He then proceeds to list the ways in which he believes he was actually prejudiced by the delay. Id. at PageID 1575-80. Klusty concludes: Ohio courts and the Magistrate Judge appear to have adopted a heighted [sic; presumably “heightened” is intended] standard concerning the issue of pre-indictment delay, denying any relief where a defendant cannot point to a specific outcome that would have resulted but for the unreasonable delay. Respectfully, predicting the future is an impossible task, and certainly not is what

1 The original indictment was dismissed without prejudice and Klusty was not re-indicted for ten years. required by law. Rather, the Constitution merely requires a criminal defendant to demonstrate actual prejudice.

(ECF No. 24, PageID 1580.) The Report noted that “[t]he parties agree that the Supreme Court decision in Lovasco, 431 U.S. 783, is the relevant precedent.” (Report, ECF No. 12, PageID 1519-20). The record citations to where that agreement occurs are in the Return of Writ (ECF No. 6, PageID 339) and the Reply (ECF No. 10, PageID 1502). Since the Reply was filed, Klusty has obtained new counsel (ECF No. 18, 21). New counsel does not explicitly repudiate prior counsel’s acceptance of Lovasco as

the controlling law, but argues the Objections in terms of Doggett. Doggett was a 5-4 decision of the Supreme Court which held that an eight-and-a-half year delay between indictment and arrest violated Doggett’s Sixth Amendment Speedy Trial right without a showing of particularized trial prejudice. The Court applied the factors for analyzing speedy trial claims it had adopted in Barker v. Wingo, 407 U.S. 514 (1972): “whether delay before

trial was uncommonly long, whether the government or the criminal defendant is more to blame for that delay, whether, in due course, the defendant asserted his right to a speedy trial, and whether he suffered prejudice as the delay's result.” Doggett, 505 U.S. at 651, citing Barker, supra, at 530. Unlike Klusty, Doggett did not know of the charges against him until he was arrested. Doggett, 505 U.S. at 653-54. It noted that the most serious form of prejudice recognized in Barker was

inability to prepare a defense. Id. It held “Once triggered by arrest, indictment, or other official accusation, . . . the speedy trial enquiry must weigh the effect of delay on the accused's defense just as it has to weigh any other form of prejudice that Barker recognized.” Id. citing Moore v. Arizona, 414 U.S. 25, 26-27, and n.2 (1973); Barker, supra, at 532; Smith, supra, at 377-79; and United States v. Ewell, 383 U.S. 116, 120 (1966) 120. While it indulged a presumption of prejudice from long and unjustified government delay, it held that presumption could be rebutted.

Neither the Report nor the Fifth District’s decision is inconsistent with Doggett. First of all, Doggett did not purport to change the standard in Lovasco which is cited approvingly, 505 U.S. at 666. Second, as a critical matter, Klusty knew of the charges and thus had an opportunity and incentive to prepare a defense when he was first indicted. Third, the Fifth District decision did not impose an outcome-determinative test of prejudice on Klusty, but weighed each particular

claim of prejudice individually. That is, it did not declare Klusty was not prejudiced because he could not show the outcome would have been different with an earlier trial, but found the likely impact of prejudice in each particular instance was minimal or speculative. The Report also does not impose an outcome-determinative test of Klusty’s case and it does not purport to decide the speedy trial claim de novo. Rather, because the Fifth District decided

Klusty’s constitutional issue, we must decide if its decision was objectively unreasonable. Having reviewed that decision on the merits, the Magistrate Judge again finds it is consistent with Barker, Lovasco, and Doggett. It is therefore entitled to deference under 28 U.S.C. § 2254(d)(1).

Ground Two: Faulty Answer to the Jury’s Question About Delay

Klusty’s trial jury propounded questions about the age of the case and the trial judge instructed them that the age of the case was irrelevant. In his Second Ground for Relief, Klusty argues that the trial judge’s failure to instruct the jury that the delay was entirely caused by the State violated his right to due process. The Fifth District concluded the failure to give the instruction requested by Klusty was not an abuse of discretion. Klusty, 201-Ohio-2843, ¶¶ 24-28. The Report concluded that the instruction actually given did not convey the impression that

Klusty caused the delay, but rather that the cause of the delay was not relevant to their consideration.

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Related

M'culloch v. State of Maryland
17 U.S. 316 (Supreme Court, 1819)
Lochner v. New York
198 U.S. 45 (Supreme Court, 1905)
United States v. Ewell
383 U.S. 116 (Supreme Court, 1966)
Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Moore v. Arizona
414 U.S. 25 (Supreme Court, 1973)
United States v. Lovasco
431 U.S. 783 (Supreme Court, 1977)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
Keith A. Mira v. Ronald C. Marshall
806 F.2d 636 (Sixth Circuit, 1986)

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Klusty v. Krueger, Counsel Stack Legal Research, https://law.counselstack.com/opinion/klusty-v-krueger-ohsd-2020.