Knight v. Carter

CourtDistrict Court, N.D. Alabama
DecidedAugust 31, 2022
Docket7:22-cv-00037
StatusUnknown

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

Bluebook
Knight v. Carter, (N.D. Ala. 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION

REED MAX KNIGHT, ) ) Petitioner, ) ) v. ) Case No. 7:22-cv-00037-LSC-NAD ) KAREN CARTER, Warden, et al., ) ) Respondents. )

MEMORANDUM OPINION

Petitioner Reed Max Knight filed a counseled petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. Doc. 1. Petitioner Knight challenges his 2012 conviction in the Circuit Court for Tuscaloosa County, Alabama, for solicitation of murder, and his resulting 25-year sentence. Doc. 1. On July 29, 2022, the magistrate judge entered a report pursuant to 28 U.S.C. § 636(b), recommending that the court deny and dismiss Knight’s petition. Doc. 7. Through counsel, Knight filed timely objections to the report and recommendation. Doc. 8. Having carefully reviewed and considered de novo the materials in the court file, including the report and recommendation, and Knight’s objections, the court OVERRULES Knight’s objections. The court ADOPTS the magistrate judge’s report and ACCEPTS the recommendation. For the reasons stated below, Knight’s petition for a writ of habeas corpus (Doc. 1) is DENIED and DISMISSED WITH PREJUDICE. DISCUSSION

The report recommended that the court should deny and dismiss Petitioner Knight’s petition because the Alabama Court of Criminal Appeals rejected Knight’s claim for ineffective assistance of counsel under Strickland v. Washington, 466 U.S.

668 (1984), and there was no basis for relief under 28 U.S.C. § 2254, and because Knight’s claim under Giglio v. United States, 405 U.S. 150 (1972), was both abandoned and meritless. Doc. 8. Importantly (and as explained in the report and recommendation, Doc. 7 at

19, 26), the Court of Criminal Appeals “agreed” with the state trial court’s credibility determination regarding an affidavit from Knight’s trial counsel (Swords) about the strategic decision not to call an inmate (Burrell) as a witness at Knight’s trial. Doc.

4-32 at 29. In an evidentiary hearing on Knight’s post-conviction Rule 32 petition in the state trial court, Swords had testified that he did not call inmate Burrell as a witness because Burrell was not available. Doc. 4-26 at 60, 70; Doc. 7 at 14. According to Knight, Burrell would have provided testimony calling into question

the credibility of the prosecution’s key witness, who also was an inmate (Smith). Doc. 1; Doc. 8. After the Rule 32 hearing, Swords submitted an affidavit stating that he had not reviewed his trial notes before the Rule 32 hearing, and that—having

reviewed his notes—he remembered that he had made the strategic decision not to call Burrell as a witness because Burrell was an inmate. Doc. 4-28 at 68; Doc. 7 at 16. The state trial court relied on Swords’ post-hearing affidavit, finding it credible,

and the Court of Criminal Appeals “agreed.” Doc. 4-24 at 2; Doc. 4-32 at 29; Doc. 7 at 17–19. In his objections to the report and recommendation, Knight argues that

summary disposition would be inappropriate under Federal Rule of Civil Procedure 56, and requests discovery in support of his ineffective assistance of counsel claim. Knight also argues that he is entitled to relief under 28 U.S.C. § 2254(d)(1). Doc. 8. I. Summary disposition is appropriate (on the record evidence), and Knight’s objections fail to show “good cause” for discovery at this time. Summary disposition is appropriate (on the record evidence), and Knight’s objections fail to show good cause for discovery in this case. Knight’s objections

first argue that, under Rule 56, “the report and recommendation err in urging summary disposition of [the] petition.” Doc. 8 at 2. According to Knight, “the question is whether there is a genuine issue of material fact about the ability of

Knight to prove, by ‘clear and convincing’ evidence, that Swords’ decision against calling Burrell was not a ‘strategic decision,’ but was instead a significantly regrettable error.” Doc. 8 at 3–4 (citations omitted).

It is true that “[t]he Federal Rules of Civil Procedure generally govern habeas proceedings” (Banister v. Davis, 140 S. Ct. 1698, 1705 (2020)), and that, “[a]s a general principle, Rule 56 of the Federal Rules of Civil Procedure is applicable in habeas corpus cases” (McBride v. Sharpe, 25 F.3d 962, 969 (11th Cir. 1994)). But, the Federal Rules of Civil Procedure “give way . . . , if and to the extent

‘inconsistent with any statutory provisions or [habeas] rules.’” Banister, 140 S. Ct. at 1705 (citation omitted).1 As explained in the report and recommendation, under § 2254, a state prisoner

is entitled to federal habeas relief only if the state court’s adjudication of an issue (1) “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by” the United States Supreme Court, or (2) was “based on an unreasonable determination of the facts in light of the evidence presented” in

state court. Doc. 7 at 20–21 (citing 28 U.S.C. § 2254(d)). Knight argues in his objections that he is entitled to relief under 28 U.S.C. § 2254(d)(1). See, e.g., Doc. 8 at 6.

In this regard, the U.S. Supreme Court has held that “review under § 2254(d)(1) is limited to the record that was before the state court that adjudicated the claim on the merits”; section 2254(d)(1) “requires an examination of the state- court decision at the time it was made,” and “the record under review is limited to

1 See Fed. R. Civ. P. 81(a)(4) (“These rules apply to proceedings for habeas corpus . . . to the extent that the practice in those proceedings: (A) is not specified in a federal statute, the Rules Governing Section 2254 Cases, or the Rules Governing Section 2255 Cases . . . .”); Rule 12, Rules Governing Section 2254 Cases (“The Federal Rules of Civil Procedure, to the extent that they are not inconsistent with any statutory provisions or these rules, may be applied to a proceeding under these rules.”). the record in existence at that same time, i.e., the record before the state court.” Cullen v. Pinholster, 563 U.S. 170, 181–82 (2011). So, “[i]f a claim has been

adjudicated on the merits by a state court, a federal habeas petitioner must overcome the limitations of § 2254(d)(1) on the record that was before that state court.” Id. at 185. That “Pinholster restriction applies to § 2254(d)(2) claims, as well.” Landers

v. Warden, Atty. Gen.

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Related

Giglio v. United States
405 U.S. 150 (Supreme Court, 1972)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Bracy v. Gramley
520 U.S. 899 (Supreme Court, 1997)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Borden v. Allen
646 F.3d 785 (Eleventh Circuit, 2011)
Robert Consalvo v. Secretary, Department of Corrections
664 F.3d 842 (Eleventh Circuit, 2011)
Christopher Taft Landers v. Warden
776 F.3d 1288 (Eleventh Circuit, 2015)
Nejad v. Attorney General
830 F.3d 1280 (Eleventh Circuit, 2016)
Billy Raulerson v. Warden
928 F.3d 987 (Eleventh Circuit, 2019)
City of Miami Gardens v. Wells Fargo & Co.
931 F.3d 1274 (Eleventh Circuit, 2019)
Banister v. Davis
590 U.S. 504 (Supreme Court, 2020)
Donald Burns v. Town of Palm Beach
999 F.3d 1317 (Eleventh Circuit, 2021)
Cullen v. Pinholster
179 L. Ed. 2d 557 (Supreme Court, 2011)

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Knight v. Carter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/knight-v-carter-alnd-2022.