Kremer v. Erdos

District Court, S.D. Ohio·Decided December 29, 2020·No. 1:20-cv-00194·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI

VINCENT KREMER,

Petitioner, : Case No. 1:20-cv-194

- vs - District Judge Michael R. Barrett Magistrate Judge Michael R. Merz

RON ERDOS, Warden, Southern Ohio Correctional Facility,

: Respondent. SUPPLEMENTAL REPORT AND RECOMMENDATIONS

This habeas corpus case is before the Court on Petitioner’s Objections (ECF No. 18) to the Magistrate Judge’s “Report and Recommendations; Decision and Order Denying Motion to Certify” (“R&R/D&O,” ECF No. 13). District Judge Barrett has recommitted the case for reconsideration in light of the Objections (ECF No. 19). Kremer raises five objections which will be considered here in the order in which they are presented.

Objection One: The novel state-law issues should be certified to the Ohio Supreme Court

Shortly after this case was filed, Petitioner moved to certify the following questions to the Supreme Court of Ohio: 1. Does a substance absent from the Ohio or federal controlled substances schedules, but present on the federal temporary schedule, satisfy the definition of controlled substance under R.C. 3719.01(C) to constitute an Ohio offense in R.C. Chapter 2925.?

2. Does a substance absent from all controlled substances schedules, but satisfying the complex chemical formula from O.A.C. § 4729-11-02(B), fulfil the definition of controlled substance under R.C. 3719.01(A) to constitute an Ohio offense in R.C. Chapter 2925.?

(Motion to Certify, ECF No. 3, PageID 19). Opposed by Respondent, the Motion remained pending when the Magistrate Judge reference in the case was transferred to the undersigned, who denied the Motion in the same document that recommended dismissal of the Petition (R&R/D&O, ECF No. 13). Magistrate Judge decisions of non-dispositive pre-trial motions are subject to objections filed with the assigned District Judge on the same timetable as objections to recommendations on dispositive matters: fourteen days after service of the Order or R&R. Compare Fed.R.Civ.P. 72(a), (b)(2). Because of extensions of time (ECF Nos. 14, 15, 16, and 17), Petitioner’s combined objections are timely. However, they are subject to different standards of review. A Magistrate Judge’s decision of a non-dispositive pre-trial matter is to be reversed only if it is “clearly erroneous or contrary to law.” Fed.R.Civ.P. 72(a). On the other hand, a litigant is entitled to de novo review of any portion of a report and recommendation to which substantial objection is made. Fed.R.Civ.P. 72(b)(3). The Objections treat the Magistrate Judge’s ruling on the certification motion as a recommendation (ECF No. 18, PageID 431). However, the undersigned did not make a recommendation on that motion, but decided it. (R&R/D&O ECF No. 13, PageID 425-26). The Objections nowhere question the propriety of characterizing the Motion to Certify as a non- dispositive pretrial matter, which an assigned Magistrate Judge is authorized to decide in the first instance. 28 U.S.C. § 636(b)(1)(A). Litigants do not have the right to have questions of state law certified from this Court to the Supreme Court of Ohio, nor is the Supreme Court of Ohio obliged to answer the certified question. Rather the practice for certification is spelled out in Ohio Supreme Court Practice Rule

9. It is modeled on the Uniform Certification of Questions of Law Act promulgated by the Commissioners on Uniform State Laws. Its adoption in Ohio as a Supreme Court Rule of Practice is the result of collaboration between District Judge Walter Rice of this Court and the late Thomas Moyer when he was Chief Justice of Ohio. The Rule is designed to avoid the cumbersome practice under Railroad Comm’n v. Pullman Co., 312 U.S. 496 (1941), in which a federal court would abstain from exercising jurisdiction until state court litigation had been commenced and completed through appeal to obtain an answer to a controlling state law question. See Rebecca A. Cochran Federal Court Certification of Questions of State Law to State Courts: A Theoretical and Empirical Study, J. OF LEG., Vol. 29: Iss. 2, Art. 1 at 160 (2013).1 The undersigned denied the certification motion because he had recommended dismissing

the Petition (which would make the Motion moot) and because the Supreme Court of Ohio had declined to consider the same questions when Kremer sought direct review (R&R/D&O, ECF No. 13, PageID 425-26). Kremer objects that because his case is unique – the only prosecution in Ohio thus far for the substances he was convicted of trafficking – this Court cannot decide this case without an answer from the Supreme Court of Ohio to his proposed state law questions. He argues: Kremer’s federal constitutional claims turn on whether the Ohio legislature criminalized the possession and trafficking of 25C- NBOMe and Fluoro-AMB at the time of his acts. If prosecuted and incarcerated for non-offenses, Kremer’s custody is unconstitutional,

1 Professor Cochran’s article is an empirical study of how certification has actually worked in Ohio. She is quite skeptical that it has achieved the results that were hoped for. and he is entitled to the writ. But if the Ohio legislature criminalized these substances at the time of his acts, Kremer lacks a federal claim.

(Objections, ECF No. 18, PageID 431). The Magistrate Judge agrees that if the two substances in question had not been made controlled substances by Ohio positive law at the time of Kremer’s conduct, then his convictions for trafficking those substances are unconstitutional. But Kremer’s further argument that the answer to those questions must come from the Supreme Court of Ohio is flawed. Federal courts themselves are authorized to decide questions of state law that arise in the exercise of their habeas jurisdiction2. More to the point, however, the Twelfth District Court of Appeals has already decided these questions of Ohio law on direct appeal in this very case: {¶ 10} Kremer challenges counts one, two, three, and six in Case No. 16CR31735 and counts five and six in Case No. 16CR32152 arguing the respective drugs, i.e., 25CNBOMe and Fluoro-AMB, were not Schedule I controlled substances at the time of his arrest.

{¶ 11} However, following review, we find Kremer's argument is without merit. In the first indictment, the state stated that Kremer trafficked and possessed “25C-NBOMe, a Schedule I controlled substance.” Likewise, the second indictment stated that Kremer possessed and trafficked “Fluoro-AMB, a schedule I controlled substance.” As a result, the challenged counts in Kremer's indictments properly identified the schedule of the drug. Therefore, the indictments satisfy Jackson for purposes of identifying the drug offense. Kremer's claim otherwise lacks merit.

{¶ 12} In reaching this decision, we also disagree with Kremer's contention that forms the basis of this assignment of error. Though he claims otherwise, 25C-NBOMe and Fluoro-AMB were both Schedule I controlled substances at the time of his arrest. 21 C.F.R. 1308.11(h)(5); Ohio Adm.Code 4729-11-02(B). Finally, we note the well-established law that “by pleading guilty, a defendant admits to committing the offense as charged.” State v. Jordan, 12th Dist. Warren No. CA2014-04-051, 2015-Ohio-575.

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