Laramore v. Stange

CourtDistrict Court, E.D. Missouri
DecidedMarch 31, 2024
Docket1:21-cv-00013
StatusUnknown

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

Bluebook
Laramore v. Stange, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

DENNIS LYNN LARAMORE, ) ) Petitioner, ) ) v. ) No. 1:21-CV-00013 SPM ) BILL STANGE, ) ) Respondent. )

MEMORANDUM AND ORDER This matter is before the undersigned on the petition of Missouri state prisoner Dennis Lynn Laramore (“Petitioner”) for a writ of habeas corpus pursuant to 28 U.S.C.A. § 2254 (Doc. 1). The parties have consented to the jurisdiction of the undersigned United States Magistrate Judge pursuant to 28 U.S.C.A. § 636(c)(1) (Doc. 1). Petitioner filed a motion requesting an evidentiary hearing and appointment of counsel (Doc. 19) and a Memorandum to Clerk re: Court’s Mistake as to Doc. 21, Memorandum & Order (Doc. 22). For the following reasons, the petition will be dismissed and Petitioner’s subsequent motions will be denied. I. BACKGROUND Petitioner is a Missouri state prisoner currently serving a twenty-year sentence for unlawful possession of a firearm pursuant to a 2017 conviction. In his petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254, Petitioner raised five grounds for habeas relief: (1) that the trial court did not permit him to proceed pro se at his trial; (2) that the trial court violated his protection against double jeopardy when he was convicted of eight separate counts of possession of a firearm; (3) that the state did not present sufficient evidence at trial to prove his guilt beyond a reasonable doubt; (4) that his appellate counsel was ineffective in not briefing the issue of whether a docket sheet could be used as evidence to show that Petitioner was a prior and persistent offender; and (5) that Petitioner was denied a fair and impartial jury because three venirepersons demonstrated bias against him during voir dire (Doc. 1). Respondent argued that all five grounds for relief should be denied, because Grounds 1, 2, and 5 have been procedurally defaulted and Grounds 3 and 4 were reasonably adjudicated on the merits in state court (Doc. 8).

After the response was filed, Petitioner filed two Motions to File Supplemental Exhibits Out of Time with Leave of Court, asking the Court to supplement the record with various exhibits (Doc. 10, 11). The Court denied those requests, without prejudice, finding that Petitioner had not shown how they were relevant to any of the claims in the petition and that Petitioner had not set forth any facts or arguments from which the Court could determine whether expansion of the record was permissible under the relevant legal requirements (Doc. 15). Petitioner refiled the Requests to File Supplemental Exhibits Out of Time with Leave of Court, again asking the Court to supplement the record with various exhibits (Doc. 16). The Court denied Petitioner’s motion, with prejudice (Doc. 21). Petitioner then filed a Motion Requesting an Evidentiary Hearing and

Appointment of Counsel (Doc. 19), and a Memorandum to Clerk re: Court’s Mistake as to Doc. 21 Memorandum & Order (Doc. 22). II. LEGAL STANDARDS A. LEGAL STANDARD FOR REVIEWING CLAIMS ON THE MERITS An individual in custody under the judgment and sentence of a state court may seek habeas relief under the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), 28

U.S.C. § 2254(a), “only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a). Federal habeas review exists only “as ‘a guard against extreme malfunctions in the state criminal justice systems, not a substitute for ordinary error correction through appeal.’” Woods v. Donald, 575 U.S. 312, 316, (2015) (per curiam) (quoting Harrington v. Richter, 562 U.S. 86, 102-03 (2011)). Accordingly, “[i]n the habeas setting, a federal court is bound by AEDPA to exercise only limited and deferential review of underlying state court decisions.” Lomholt v. Iowa, 327 F.3d 748, 751 (8th Cir. 2003) (citing 28 U.S.C. § 2254). Under AEDPA, a federal court may not grant habeas relief to a state

prisoner with respect to any claim that was adjudicated on the merits in the state court proceedings unless the state court’s adjudication of a claim “(1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” 28 U.S.C. § 2254(d). A state court decision is “contrary to” clearly established Supreme Court precedents “if the state court applies a rule that contradicts the governing law set forth in [the Supreme Court’s] cases” or “if the state court confronts a set of facts that are materially indistinguishable from a decision of [the Supreme] Court and

nevertheless arrives at a result different from [the Supreme Court’s] precedent.” Williams v. Taylor, 529 U.S. 362, 405-06 (2000); see also Brown v. Payton, 544 U.S. 133, 141 (2005). A state court decision involves an “unreasonable application” of clearly established federal law if it “correctly identifies the governing legal rule but applies it unreasonably to the facts of a particular prisoner’s case.” Williams, 529 U.S. at 407-08; see also Bell v. Cone, 535 U.S. 685, 694 (2002). “Finally, a state court decision involves an unreasonable determination of the facts in light of the evidence presented in the state court proceedings only if it is shown that the state court’s presumptively correct factual findings do not enjoy support in the record.” Jones v. Luebbers, 359 F.3d 1005, 1011 (8th Cir. 2004) (citations and internal quotation marks omitted); see also Rice v. Collins, 546 U.S. 333, 338-39 (2006) (noting that state court factual findings are presumed correct unless the habeas petitioner rebuts them through clear and convincing evidence) (citing 28 U.S.C. § 2254(e)(1)). B. LEGAL STANDARD FOR PROCEDURALLY DEFAULTED CLAIMS To preserve a claim for federal habeas review, “a state habeas petitioner must present that

claim to the state court and allow that court an opportunity to address his claim.” Moore-El v. Luebbers, 446 F.3d 890, 896 (8th Cir. 2006) (citing Coleman v. Thompson, 501 U.S. 722, 731-32 (1991)). “Where a petitioner fails to follow applicable state procedural rules, any claims not properly raised before the state court are procedurally defaulted.” Id. The federal habeas court will consider a procedurally defaulted claim “only where the petitioner can establish either cause for the default and actual prejudice, or that the default will result in a fundamental miscarriage of justice.” Id. (citing Sawyer v. Whitley, 505 U.S. 333, 338-39 (1992)). To demonstrate cause, a petitioner must show that “some objective factor external to the defense impeded [the petitioner’s] efforts to comply with the State’s procedural rule.” Murray v. Carrier, 477 U.S. 478, 488 (1986).

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Laramore v. Stange, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laramore-v-stange-moed-2024.