Lark v. Warden Southeastern Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedApril 6, 2020
Docket2:19-cv-04160
StatusUnknown

This text of Lark v. Warden Southeastern Correctional Institution (Lark v. Warden Southeastern Correctional Institution) 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
Lark v. Warden Southeastern Correctional Institution, (S.D. Ohio 2020).

Opinion

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

VERCIE L. LARK,

Petitioner, : Case No. 2:19-cv-4160

- vs - District Judge Edmund A. Sargus, Jr. Magistrate Judge Michael R. Merz

BRIAN COOK, Warden, Southeastern Correctional Institution,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case, brought pro se by Petitioner Vercie Lark under 28 U.S.C. § 2254, is before the Court for decision on the merits on the Petition (ECF No. 1), the State Court Record (ECF No. 3), and the Return of Writ (ECF No. 3). Upon ordering an answer in the case, Magistrate Judge Vascura set a deadline for Petitioner to file a reply or traverse of twenty-one days after the Return of Writ. Because the Return was filed and served by mail on December 5, 2019, the time for Petitioner to file a reply expired on December 30, 2019 (See Fed.R.Civ.P. 6). However no reply has been filed. The Magistrate Judge reference in this case has been transferred to the undersigned to help balance the Magistrate Judge workload in the District. Litigation History

On April 21, 2017, a Fayette County grand jury indicted Lark on nine counts for various violations of the controlled substances laws. The case was tried to a jury on February 15, 2018. At the conclusion of the State’s evidence, the trial judge dismissed Counts One, Five, and Seven. The jury found Lark not guilty as to Counts Two, Three and Four, but guilty as charged on Counts Six, Eight, and Nine. The trial judge then sentenced him to an aggregate term of imprisonment of fifty-one months. Lark appealed to the Twelfth District Court of Appeals which affirmed the conviction. State v. Lark, 2018-Ohio-4940 (Ohio App. 12th Dist. Dec, 10, 2018), appellate jurisdiction declined, 156 Ohio St. 3d 1453 (2019). On March 8, 2019, Lark filed an application to reopen the direct appeal to litigate a claim of ineffective assistance of appellate counsel (State Court Record, ECF No. 3, Ex. 13). The

Twelfth District denied the application. Id. at Ex. 14, appellate jurisdiction declined, 2019-Ohio- 4003 (2019). Lark then filed the instant habeas corpus petition, pleading three grounds for relief: Ground One: Insufficiency of the evidence.

Supporting Facts: Petitioner states that the pre-arrest and trial delay violated his rights to due process, violating “fundamental conception of justice,” which define the community’s sense of fair play and decency.

Ground Two: Trial court denied admission of exonerating and exculpatory evidence violating due process rights of Petitioner.

Supporting Facts: The trial court erred when it excluded evidence of the written statement of James Tanner made on August 29, 2016. The court applied the hearsay rule mechanically to defeat the ends of justice. Ground Three: Appellate counsel failed to submit an assignment of error that trial counsel erred and was deficient for failing to raise the issue of prejudicial delay.

Supporting Facts: The state violated due process and caused actual prejudice which was unjustifiable; the pre-indictment delay. The evidence from the record is sufficient to show pre-indictment delay as the State of Ohio made the declarant unavailable to the Defendant and his counsel.

(Petition, ECF No. 1, PageID# 5-8).

Analysis

Ground One: Conviction Based on Insufficient Evidence

In his First Ground for Relief, Lark claims he was convicted on insufficient evidence1. Respondent concedes this claim is preserved for merits review in habeas corpus. An allegation that a verdict was entered upon insufficient evidence states a claim under the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Jackson v. Virginia, 443 U.S. 307 (1979); In re Winship, 397 U.S. 358 (1970); Johnson v. Coyle, 200 F.3d 987, 991 (6th Cir. 2000); Bagby v. Sowders, 894 F.2d 792, 794 (6th Cir. 1990)(en banc). In order for a conviction to be constitutionally sound, every element of the crime must be proved beyond a reasonable doubt. In re Winship, 397 U.S. at 364. [T]he relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt . . . . This familiar standard gives full play to the

1 The “supporting facts” portion of this claim as pleaded in the Petition appears to be in support of the Third Ground for Relief rather than the First. responsibility of the trier of fact fairly to resolve conflicts in the testimony, to weigh the evidence and to draw reasonable inferences from basic facts to ultimate facts.

Jackson v. Virginia, 443 U.S. at 319; United States v. Paige, 470 F.3d 603, 608 (6th Cir. 2006); United States v. Somerset, 2007 U.S. Dist. LEXIS 76699 (S.D. Ohio 2007). This rule was recognized in Ohio law at State v. Jenks, 61 Ohio St. 3d 259 (1991). Of course, it is state law which determines the elements of offenses; but once the state has adopted the elements, it must then prove each of them beyond a reasonable doubt. In re Winship, supra. A sufficiency challenge should be assessed against the elements of the crime, not against the elements set forth in an erroneous jury instruction. Musacchio v. United States, 577 U.S. ___, 136 S. Ct. 709, 193 L. Ed. 2d 639 (2016). In cases such as Petitioner’s challenging the sufficiency of the evidence and filed after enactment of the Antiterrorism and Effective Death Penalty Act of 1996 (Pub. L. No 104-132, 110 Stat. 1214)(the “AEDPA”), two levels of deference to state decisions are required: In an appeal from a denial of habeas relief, in which a petitioner challenges the constitutional sufficiency of the evidence used to convict him, we are thus bound by two layers of deference to groups who might view facts differently than we would. First, as in all sufficiency-of-the-evidence challenges, we must determine whether, viewing the trial testimony and exhibits in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. See Jackson v. Virginia, 443 U.S. 307, 319, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979). In doing so, we do not reweigh the evidence, re- evaluate the credibility of witnesses, or substitute our judgment for that of the jury. See United States v. Hilliard, 11 F.3d 618, 620 (6th Cir. 1993). Thus, even though we might have not voted to convict a defendant had we participated in jury deliberations, we must uphold the jury verdict if any rational trier of fact could have found the defendant guilty after resolving all disputes in favor of the prosecution. Second, even were we to conclude that a rational trier of fact could not have found a petitioner guilty beyond a reasonable doubt, on habeas review, we must still defer to the state appellate court's sufficiency determination as long as it is not unreasonable. See 28 U.S.C. § 2254(d)(2).

Brown v. Konteh, 567 F.3d 191, 205 (6th Cir. 2009). In a sufficiency of the evidence habeas corpus case, deference should be given to the trier-of-fact's verdict under Jackson v.

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Lark v. Warden Southeastern Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lark-v-warden-southeastern-correctional-institution-ohsd-2020.