LEWIS v. ZAKEN

CourtDistrict Court, E.D. Pennsylvania
DecidedSeptember 4, 2025
Docket2:23-cv-02387
StatusUnknown

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

Bluebook
LEWIS v. ZAKEN, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

JULMAL LEWIS : CIVIL ACTION : v. : NO. 23-2387 : RANDY EVANS, THE ATTORNEY : GENERAL OF THE STATE OF : PENNSYLVANIA, THE DISTRICT : ATTORNEY OF PHILADELPHIA : COUNTY, PHILADELPHIA :

MEMORANDUM

MURPHY, J. September 4, 2025

Before us are Julmal Lewis’s objections to Magistrate Judge Hey’s report and recommendation denying Mr. Lewis’s habeas petition and affirming the Pennsylvania Superior Court’s PCRA ruling. For the reasons explained in this memorandum, we overrule all of Mr. Lewis’s objections and adopt Judge Hey’s R&R in full. I. Background1 On March 9, 2009, following a jury trial in the Philadelphia Court of Common Pleas, Julmal Lewis was sentenced to an aggregate term of nineteen and one-half to thirty-nine years’ imprisonment. The sentence consisted of consecutive terms of ten to twenty years for voluntary manslaughter and seven to fourteen years for aggravated assault, together with a consecutive term of two and one-half to five years for carrying a firearm without a license. See Commonwealth v. Lewis, CP-51-CR-0010116-2007, Order Sentencing (Phil. C.C.P. Mar. 9, 2009); DI 17 at 114. The convictions arose from the April 28, 2007, shootings of Rasheen Johnson, who was killed, and Omar Ingram, who was wounded.

1 Mr. Lewis does not specifically object to the procedural history provided by Judge Hey in her R&R. Upon review, we adopt it, and the reader may refer to the R&R for a more detailed description. See DI 21 at 1-7. Lewis filed a direct appeal but discontinued it on January 19, 2010. See DI 17 at 149 (ECF) (Commonwealth v. Lewis, No. 837 EDA 2009 (Pa. Super. Jan. 21, 2010) (order granting discontinuance)). He then sought relief under Pennsylvania’s Post Conviction Relief Act (PCRA), raising ineffective-assistance claims related to the jury instructions and to sentencing.

The PCRA court granted partial relief by ordering resentencing based on an erroneous prior record score, and on October 26, 2012, reimposed the same aggregate sentence. See id. at 219 (ECF) (Commonwealth v. Lewis, CP-51-CR-0010116-2007 (C.P. Phila. Oct. 26, 2012) (resentencing order)). Lewis appealed from that resentencing, again attempting to litigate his ineffective- assistance claims. On May 13, 2015, the Pennsylvania Superior Court held that those claims were not cognizable on direct review and affirmed the judgment of sentence. See Commonwealth v. Lewis, No. 710 EDA 2013, 2015 WL 7260909, at *2 (Pa. Super. May 13, 2015). On August 27, 2015, Lewis filed another PCRA petition seeking to reinstate his right to

appeal the denial of his ineffective-assistance claims nunc pro tunc. See DI 17 at 274 (ECF) (Commonwealth v. Lewis, CP-51- CR-0010116-2007, Petition Requesting to Reinstate Appeal Nunc Pro Tunc (Phil. C.C.P. Aug. 27, 2015)). The PCRA court granted relief in February 2020, and Lewis pursued a nunc pro tunc appeal. See id. at 290 (ECF). The Superior Court ultimately affirmed the denial of PCRA relief on the merits, concluding that none of Lewis’s ineffective- assistance claims warranted relief. See Commonwealth v. Lewis, No. 814 EDA 2020, 2022 WL 1132620 (Pa. Super. Apr. 18, 2022). The Pennsylvania Supreme Court later denied allowance of appeal. See id. at 393 (ECF) (Commonwealth v. Lewis, No. 17 EAL 2023 (Pa. May 26, 2023)).

2 Lewis then filed the present habeas petition under 28 U.S.C. § 2254, raising three ineffective-assistance claims: (1) trial counsel’s failure to ensure that the jury was properly instructed on self-defense as to the aggravated assault charge, (2) trial counsel’s failure to request an involuntary manslaughter instruction, and (3) appellate counsel’s failure to pursue a claim that

the trial court erred in overruling an objection to the prosecutor’s remarks during closing argument. See DI 2; DI 5. The petition was referred to Magistrate Judge Hey, who issued a R&R, recommending denial of the petition. See DI 21. Lewis has filed objections, organized into four groups: general objections and three objections directed to each of his substantive claims. See DI 23. We review de novo those portions of the R&R to which Mr. Lewis has made specific objections. 28 U.S.C. § 636(b)(1). For the reasons that follow, we conclude that none of Lewis’s objections has merit. Accordingly, we will adopt the R&R, overrule the objections, and deny the petition. II. Legal standard

When a party objects to a magistrate judge’s report and recommendation, we conduct de novo review of the portions of the report to which specific objections are made. 28 U.S.C. § 636(b)(1); Fed. R. Civ. P. 72(b). Absent objections, we still give “reasoned consideration” to the remaining portions of the R&R. Equal Emp. Opportunity Comm’n v. City of Long Branch, 866 F.3d 93, 100 (3d Cir. 2017) (quoting Henderson v. Carlson, 812 F.2d 874, 878 (3d Cir. 1987)). We may accept, reject, or modify the recommended disposition. Our review of a state conviction on habeas corpus is circumscribed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). A federal court may not grant relief on a

3 claim adjudicated on the merits in state court unless the state court’s decision (1) “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) “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).

Factual determinations by a state court are “presumed to be correct,” and the petitioner bears the burden of rebutting the presumption by clear and convincing evidence. Id. § 2254(e)(1); see Werts v. Vaughn, 228 F.3d 178, 196 (3d Cir. 2000). A state-court decision is “contrary to” clearly established federal law if it “applies a rule that contradicts the governing law set forth in [the Supreme Court’s] cases,” or if it confronts a set of facts that are materially indistinguishable from a Supreme Court decision and arrives at a different result. Williams v. Taylor, 529 U.S. 362, 405-06 (2000). A state-court decision is an “unreasonable application” of federal law if the court correctly identifies the governing rule but applies it unreasonably to the facts of the case. Id. at 407-08. The standard is demanding: “an unreasonable application of federal law is different from an incorrect application of federal law,”

and relief is available only where the state court’s decision was objectively unreasonable. Id. at 410-11; see Werts, 228 F.3d at 196. Lewis’s claims all allege ineffective assistance of counsel. Such claims are governed by Strickland v. Washington, 466 U.S. 668 (1984). To prevail, a petitioner must show both that counsel’s performance was constitutionally deficient and that the deficient performance prejudiced the defense. Id. at 687. Deficient performance means errors so serious that counsel was not functioning as the “counsel” guaranteed by the Sixth Amendment. Id. at 688.

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LEWIS v. ZAKEN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lewis-v-zaken-paed-2025.