Leal v. Hutchings

District Court, D. Nevada·Decided November 15, 2022·No. 2:21-cv-00595·Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 4 Jack Leal, Case No. 2:21-cv-00595-JAD-VCF

5 Petitioner Order Denying Petition for Habeas Relief and 6 v. Closing Case 7 Brian Williams,1 et al., [ECF No. 8] 8 Respondents 9 Petitioner Jack Leal brings this pro se habeas corpus petition under 28 U.S.C. § 2254 to 10 challenge his 2017 Nevada state-court conviction after a guilty plea to multiple transactions 11 involving fraud or deceit in the course of an enterprise and occupation.2 Leal was sentenced to 12 six to fifteen years in prison and ordered to pay $757,420.00 in restitution.3 In the remaining 13 grounds of his petition, Leal alleges that his plea was involuntary due to the actions of his 14 codefendant, his plea was not intelligent due to the defective information, and his counsel had a 15 conflict of interest in representing him and his codefendant.4 Having evaluated the merits of 16 those claims, I find that habeas relief is not warranted, so I deny Leal’s petition. I do, however, 17 grant Leal a certificate of appealability on grounds 1 and 3, and I close this case. 18 Background 19 Leal and his codefendant, Jessica Garcia, were charged in a criminal complaint with 20 racketeering, twelve counts of theft of $3,500 or more, and multiple transactions involving fraud 21 22

1 The state corrections department’s inmate-locator page states that Leal is incarcerated at Casa 23 Grande Transitional Housing. Brian Williams is the deputy director for that facility. At the end of this order, I direct the clerk to substitute Brian Williams as a respondent for Respondent 24 William Hutchings under Federal Rule of Civil Procedure 25(d). 25 2 ECF No. 12-12. 26 3 Id. Leal’s judgment of conviction was later amended, ordering Leal’s restitution to be “payable jointly and severally with [his] Co-Defendant.” ECF No. 15-5. 27 4 ECF No. 8. 28 1 or deceit in the course of an enterprise or occupation.5 Leal waived his preliminary hearing and 2 signed a conflict-of-interest waiver so that his counsel could also represent Garcia.6 The parties 3 entered into a plea agreement in which (1) Leal agreed to plead guilty to multiple transactions 4 involving fraud or deceit in the course of an enterprise or occupation; (2) Leal agreed to pay 5 restitution of $757,420.00; (3) Leal and Garcia were jointly and severally responsible for the 6 restitution; (4) if Leal paid restitution in full at or before sentencing, “the State would not oppose 7 the imposition of a term of probation not to exceed a term of five years, with a suspended 36-to- 8 90 month term of imprisonment”; and (5) if Leal did not pay restitution in full at or before the 9 time he was sentenced, “the State [would] retain the right to argue for the imposition of a term of 10 imprisonment.”7 A second, signed conflict-of-interest waiver was attached to the plea 11 agreement.8 Leal did not pay the full restitution by the time of sentencing, and the trial court 12 sentenced him to six to fifteen years in prison.9 The Nevada Court of Appeals affirmed Leal’s 13 judgment of conviction,10 and the Nevada Supreme Court denied review.11 14 Leal filed a state petition for post-conviction relief.12 The state court denied Leal’s 15 petition,13 and the Nevada Court of Appeals affirmed14 and denied rehearing.15 Leal then filed 16 two additional state petitions for post-conviction relief and two supplemental state petitions for 17

5 ECF No. 12-4 at 4–17. 18 6 Id. at 68–72. 19 7 ECF No. 12-7 at 2–3. 20 8 Id. at 14. 21 9 ECF No. 12-11 at 22. 22 10 ECF No. 14-11. 23 11 ECF No. 14-15. 24 12 ECF No. 14-20. 25 13 ECF No. 15-6. 26 14 ECF No. 16-7. 27 15 ECF No. 17-19. 28 1 post-conviction relief.16 The state court denied these additional petitions as procedurally barred 2 or barred by the law of the case.17 Leal appealed,18 and the Nevada Court of Appeals affirmed in 3 part and dismissed in part.19 4 Leal dispatched his federal habeas corpus petition on April 3, 2021.20 Respondents 5 moved to dismiss grounds 2, 3, and 4.21 I granted the motion to dismiss in part, finding that 6 ground 2 was improper in part under Tollett v. Henderson22 and ground 4 was unexhausted.23 I 7 instructed Leal to choose one of three options for proceeding in this case.24 Leal filed a 8 declaration indicating his desire to abandon ground 4 and proceed on the exhausted grounds.25 I 9 granted Leal’s request and dismissed ground 4 without prejudice as unexhausted.26 Respondents 10 answered the remaining grounds in Leal’s petition,27 and Leal replied.28 11 Discussion 12 A. Review under the Antiterrorism and Effective Death Penalty Act (AEDPA) 13 If a state court has adjudicated a habeas corpus claim on its merits, a federal district court 14 may only grant habeas relief with respect to that claim if the state court’s adjudication “resulted 15

16 ECF Nos. 15-28, 16-1, 17-16, 17-23. 16 17 ECF No. 20-11. 17 18 ECF No. 20-13. 18 19 ECF No. 36-5. 19 20 ECF No. 8. 20 21 ECF No. 11 at 7–10. 21 22 Tollett v. Henderson, 411 U.S. 258 (1973). 22 23 ECF No. 29. 23 24 Id. 24 25 ECF No. 30. 25 26 ECF No. 31. 26 27 ECF No. 38. 27 28 ECF No. 39. 28 1 in a decision that was contrary to, or involved an unreasonable application of, clearly established 2 [f]ederal law, as determined by the Supreme Court of the United States” or “resulted in a 3 decision that was based on an unreasonable determination of the facts in light of the evidence 4 presented in the [s]tate court proceeding.”29 A state court acts contrary to clearly established 5 federal law if it applies a rule contradicting the relevant holdings or reaches a different 6 conclusion on materially indistinguishable facts;30 it unreasonably applies clearly established 7 federal law if it engages in an objectively unreasonable application of the correct governing legal 8 rule to the facts at hand.31 Section 2254 does not, however, “require state courts to extend” 9 Supreme Court precedent “to a new context [in which] it should apply” or “license federal courts 10 to treat the failure to do so as error.”32 The “objectively unreasonable” standard is difficult to 11 satisfy;33 “even ‘clear error’ will not suffice.”34 12 Habeas relief may be granted only if “there is no possibility [that] fairminded jurists 13 could disagree that the state court’s decision conflicts with [the Supreme Court’s] precedents.”35 14 As “a condition for obtaining habeas relief,” a petitioner must show that the state-court decision 15 “was so lacking in justification that there was an error well understood and comprehended in 16 existing law beyond any possibility of fairminded disagreement.”36 “[S]o long as ‘fairminded 17 jurists could disagree’ on the correctness of the state court’s decision,” habeas relief under 18

19 29 28 U.S.C. § 2254(d). 20 30 Price v. Vincent, 538 U.S. 634, 640 (2003). 21 31 White v. Woodall, 134 S. Ct. 1697, 1705–07 (2014). 22 32 Id. at 1705–06 (emphasis in original). 23 33 Metrish v. Lancaster, 569 U.S. 351, 357–58 (2013). 24 34 Wood v. McDonald, 135 S. Ct. 1372, 1376 (2015) (per curiam) (citation omitted); see also Schriro v. Landrigan, 550 U.S. 465, 473 (2007) (“The question . . . is not whether a federal court 25 believes the state court’s determination was incorrect but whether that determination was unreasonable—a substantially higher threshold.”). 26 35 Harrington v. Richter, 562 U.S. 86, 102 (2011). 27 36 Id. at 103.

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