Lamb v. Warden, Southern Ohio Correctional Facility

CourtDistrict Court, S.D. Ohio
DecidedAugust 24, 2020
Docket1:19-cv-00621
StatusUnknown

This text of Lamb v. Warden, Southern Ohio Correctional Facility (Lamb v. Warden, Southern Ohio Correctional Facility) 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
Lamb v. Warden, Southern Ohio Correctional Facility, (S.D. Ohio 2020).

Opinion

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

TOBY LAMB II,

Petitioner, : Case No. 1:19-cv-621

- vs - District Judge Timothy S. Black Magistrate Judge Michael R. Merz

WARDEN, Southern Ohio Correctional Facility,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case, brought pro se by Petitioner Toby Lamb II, is before the Court for decision on the Petition (ECF No. 1), the State Court Record (ECF No. 8), the Return of Writ (ECF No. 9), and Petitioner’s Reply (ECF No. 11). The Magistrate Judge reference in the case has recently been transferred to the undersigned to help balance the Magistrate Judge workload in the Southern District (ECF No. 12).

Litigation History

Lamb was indicted by a Scioto County, Ohio, grand jury on charges of aggravated robbery with a firearm specification in violation of Ohio Revised Code § 2911.01(A)(1)/2911.01(C); failure to comply with the order or signal of a police officer in violation of Ohio Revised Code § 1 2921.331(B)/2921.331(C)(5)(a)(ii); and receiving stolen property in violation of Ohio Revised Code § 2913.51(A)/2913.51(C). After Lamb rejected an on-the-record plea offer, the case was tried in March 2017 and the jury convicted him of aggravated robbery with the firearm specification and failure to obey the order or signal of a police officer; the receiving stolen property charge was dismissed. The trial court sentenced Lamb to an aggregate prison term of fifteen years. With new counsel, Lamb appealed to the Ohio Fourth District Court of Appeals, raising the following assignments of error:

1. Defendant’s trial counsel was ineffective in failing to properly advise defendant of a plea offer made by the state of Ohio.

2. Appellant’s convictions for (a) aggravated robbery and (b) failure to comply were against the manifest weight and sufficiency of the evidence.

3. The trial court abused its discretion in admitting improper hearsay evidence from detective Jodi Conkel and/or failing to provide a proper curative instruction.

4. Appellant’s speedy trial rights under O.R.C. 2945.71 were violated as a matter of law.

5. A mistrial should have been declared due to improper selection of the alternate juror at trial.

6. Appellant was denied his Sixth Amendment rights to a fair trial when his pro se motions went unaddressed.

7. Cumulative errors committed during the appellant’s trial deprived him of a fair trial and require reversal of his convictions.

(Appellant’s Brief, ECF No. 8, PageID #95-118). The Fourth District overruled all of these assignments of error and affirmed the trial court. State v. Lamb 2018-Ohio-1405 (Ohio App. 4th Dist. Apr. 10, 2018), appellate jurisdiction declined, 153 Ohio St. 3d 1462 (2018). 2 During the pendency of his direct appeal, Lamb filed pro se a petition for post-conviction relief under Ohio Revised Code § 2953.21, pleading one claim: “A meaningful right to effective assistance of counsel during plea negotiations is demanded by the Sixth Amendment and is a critical component of the administration of criminal law.” (Petition, State Court Record, ECF No.

8, Ex. 32, PageID 198, et seq.) The trial court found it lacked jurisdiction to consider the petition while the direct appeal was pending and dismissed it on January 3, 2018. Id. at Ex. 33. Lamb’s appeal from that order was dismissed as untimely and for failure to perfect1 the appeal (Decision and Judgment Entry, ECF No. 8, Ex. 38). Lamb did not appeal to the Supreme Court of Ohio, but instead filed his habeas corpus petition in this case on July 17, 2019, pleading the following grounds for relief: Ground One: Ineffective counsel

Supporting Facts: Appellant informed trial and appellant [sic] counsel Detective Jodi Conkel committed perjury under oath in her testimony that appellant visited Ms. Foster while she was in jail in Dayton, Ohio. Appellant never visited Ms. Foster and neither counsel raised the issue at trial or appeal even after appellant informed them. A small investigation into my defense would have proved otherwise, he failed to correct error.

Ground Two: Ineffective assistance of counsel

Supporting Facts: March 7, 2017 trial counsel advised appellant he was facing a maximum of 14 years. Trial counsel produced a piece of paper which he said was a plea agreement of 3 years and 9 months, also that appellant had until March 13, 2017 to decide. Unrelated to the plea offer trial counsel informed appellant the 2nd indictment was being dismissed, Count 3 Receiving Stolen Property on this indictment was being dismissed as well as Count 1 Aggravated Robbery was being dropped to a Felony 2 which totals a maximum sentence of 14 years if convicted. Appellant called trial counsel the night of March 7, 2017 from a document [sic] jail phone

1 To perfect an appeal, an appellant must file or cause the filing of certain documents with the court of appeals to complete the record for the appeal. 3 to accept plea agreement and trial counsel never accepted the call. Appellant also had a family member call and attempt to contact him. Trial counsel seen appellant March 12, 2017 and informed him the offer was gone.

Ground Three: Ineffective assistance of counsel

Supporting Facts: Appellate counsel’s performance is well below an objective level of reasonable representation for arguing meritless issues to the court. Appellant informed trial counsel March 6, 2017 he was not brought to trial within speedy trial limits in which counsel went into the chambers and advised appellant he was wrong. When in fact after trial counsel calculated the time appellant spent in Montgomery County jail and realized his error then said “it was nothing we could do.”

Ground Four: Cumulative errors

Supporting Facts: Counsel failed appellant by not interviewing witnesses, appellant, and not investigating the case. By allowing Detective Conkel to perjure herself in her testimony on her blatant violation of appellant’s due process. The trial court committed multiple errors that denied appellant a fair and just trial.

Petition, ECF No. 1 PageID 6-11.)

Analysis

All four of Petitioner’s Grounds for Relief raise claims of ineffective assistance of trial counsel and/or ineffective assistance of appellate counsel. The governing standard for ineffective assistance of counsel is found in Strickland v. Washington, 466 U.S. 668 (1984): A convicted defendant's claim that counsel's assistance was so defective as to require reversal of a conviction or death sentence has two components. First, the defendant must show that counsel's performance was deficient. This requires showing that counsel was 4 not functioning as the "counsel" guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel's errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable. Unless a defendant makes both showings, it cannot be said that the conviction or death sentence resulted from a breakdown in the adversary process that renders the result unreliable.

466 U.S. at 687. In other words, to establish ineffective assistance, a defendant must show both deficient performance and prejudice. Berghuis v. Thompkins, 560 U.S. 370, 389 (2010), citing Knowles v. Mirzayance, 556 U.S.111 (2009). With respect to the first prong of the Strickland test, the Supreme Court has commanded: Judicial scrutiny of counsel's performance must be highly deferential. . . .

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Lamb v. Warden, Southern Ohio Correctional Facility, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lamb-v-warden-southern-ohio-correctional-facility-ohsd-2020.