Maiden v. Payne

CourtDistrict Court, E.D. Arkansas
DecidedAugust 24, 2020
Docket4:20-cv-00724
StatusUnknown

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

Bluebook
Maiden v. Payne, (E.D. Ark. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

DONNIE MAIDEN, * ADC #154687, * * Petitioner, * v. * No. 4:20-cv-00724-JJV * DEXTER PAYNE, Director, * Arkansas Division of Correction, * * Respondent. *

MEMORANDUM AND ORDER

I. INTRODUCTION

Petitioner Donnie Maiden, an inmate at the East Regional Unit of the Arkansas Division of Correction, brings this 28 U.S.C. § 2254 Petition for Writ of Habeas Corpus. (Doc. No. 1). Mr. Maiden was convicted by a jury in Pulaski County, Arkansas, of capital murder. (Doc. No. 5, at 2). He was sentenced to a term of life imprisonment without parole. (Id.) The Arkansas Supreme Court summarized the basic facts of the case as follows: On November 7, [2011] Tim Bradley and [Kylaus] Williams, along with Bradley’s cousin, Leroy Butler, drove to a motel, where they picked up [Donnie] Maiden and [Trenell] Emerson. The five drove to another hotel, and Bradley exited the car to purchase a drink from a nearby convenience store. While he was gone, Williams left to sell some marijuana for Maiden. As they were waiting to hear from Williams, Butler left. Williams later called and reported that he had been robbed and asked them to pick him up. Maiden drove, Emerson was in the seat behind him, and Bradley was in the passenger’s seat. After arriving at Williams’s location, Maiden joined Emerson in the backseat of the car, and Williams drove the four of them to “B. house” at Maiden’s request. Upon their arrival at B. house, Williams stopped the car and Bradley began to exit the car to use the restroom. Maiden then opened his door to exit the car and shot Williams, and Bradley took off running. Maiden dragged Williams’s body out of the car, and he and Emerson left the scene. Maiden and Emerson eventually abandoned the car and ran. Maiden then called a taxi, which took him and Emerson to a hotel in downtown Little Rock. Subsequently, they bought bus tickets and boarded a Greyhound bus to California. Using the cell phone number that the men had used to register at the hotel, Arkansas police tracked the GPS coordinates of the phone and were able to determine the men’s location. The bus was stopped by police in Phoenix, Arizona, and the men were taken into custody by the Phoenix police.

(Doc. No. 1, at 21-22). On direct appeal, Mr. Maiden argued the circuit court (1) abused its discretion when it prevented him from impeaching Tim Bradley with his prior acts of untruthfulness; (2) abused its discretion when it prevented him from impeaching Trenell Emerson with his prior inconsistent statements; (3) erred in denying his motion for mistrial based on discovery violations; (4) the overlap of Arkansas Code Annotated sections 5-10-101(a)(4) and 5-10-102(a)(2) (Repl. 2013) violates article 2, section 3, of the Arkansas Constitution; (5) committed reversible error when it ridiculed defense counsel in the jury’s presence; and (6) abused its discretion when it failed to conduct a hearing pursuant to Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993). (Id. at 20-21.) The Arkansas Supreme Court rejected each argument and affirmed his conviction and sentence. (Id. at 42.) Mr. Maiden subsequently filed a timely petition for post-conviction relief pursuant to Arkansas Rule of Criminal Procedure 37.1. (Doc. No. 1, at 43-46). He asserted twenty-six grounds for relief, including ineffective assistance of counsel and prosecutorial misconduct. (Doc. No. 5. Ex. F, at 73). The circuit court denied Mr. Maiden’s petition for post-conviction relief without a hearing stating that he failed to satisfy the Strickland test and failed to state cognizable grounds for relief under Arkansas Rule of Criminal Procedure 37. (Id. at 77.) Mr. Maiden appealed to the Arkansas Supreme Court and asserted the circuit court erred with respect to its decision to deny relief on four of his claims of ineffective assistance of counsel and for an extension of time to file a reply brief in the appeal. (Doc. No. 1, at 48.) The court denied relief stating it was clear from the face of Mr. Maiden’s petition that he did not substantiate grounds for relief. (Id.) Without a hearing, the Arkansas Supreme Court denied the motion for extension brief time and affirmed the circuit court’s order. (Id.) In the Petition for Writ of Habeas Corpus now before the Court, Mr. Maiden raises several claims for relief. (Doc. No. 1). He alleges (1) the trial court erred by preventing him from impeaching Trenell Emerson with his prior inconsistent statements under Ark. R. Evid. 608; (2)

the trial court erred by denying his motion for mistrial due to the prosecutor’s discovery violation under Ark. R. Crim. P. 17; (3) Ark. Code Ann. §§ 5-10-101(a)(4) and 5-10-02(a)(2) (Repl. 2013), overlap in violation of the Arkansas Constitution; (4) the trial court committed reversible error when it ridiculed defense counsel in the jury’s presence; (5) the trial court abused its discretion by failing to conduct a Daubert hearing before admitting expert testimony about a palm print found at the scene of the murder; and (6) ineffective assistance of counsel. (Doc. No. 1, at 16-18.) Respondent contends that claims 1-3 fail to state a federal constitutional claim; claims 4-5 are procedurally defaulted; claims 6.2, 6.7, 6.8, and 6.9 were reasonably adjudicated on the merits by the Arkansas Supreme Court; and the remaining sub-points under claim 6 are procedurally

defaulted. (Doc. No. 5, at 5). After careful consideration of the Petition and Response, the I find the Petition must be dismissed with prejudice. II. ANALYSIS A. Failure to State a Constitutional Claim A person seeking habeas relief in the United States District Court is required to bring a claim that “he is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C.A. § 2254(a); see also, e.g., Evanstad v. Carlson, 470 F.3d 777, 782 (8th Cir. 2006) (“’[F]ederal habeas corpus relief does not lie for errors of state law . . . [and] it is not the province of a federal habeas court to reexamine state-court determinations on state-law questions.’”) (quoting Estelle v. McGuire, 502 U.S. 62, 67-68 (1991)). Mr. Maiden’s claims that (1) the trial court erred by preventing him from impeaching Trenell Emerson with his prior inconsistent statements under Ark. R. Evid. 608; (2) the trial court erred by denying his motion for mistrial due to the prosecutor’s discovery violation under Ark. R. Crim. P. 17; and (3) Ark. Code Ann. §§ 5- 10-101(a)(4) and 5-10-02(a)(2) (Repl. 2013), overlap in violation of the Arkansas Constitution, are premised on state law and cannot be the basis for habeas relief. Therefore, Mr. Maiden’s claims

1-3 are not subject to federal habeas relief. B. Procedural Default Before filing a federal habeas petition, a state inmate must first “fairly present” the substance of his or her federal habeas claims to the appropriate state courts. Murphy v. King, 652 F.3d 845, 848-49 (8th Cir. 2011) (citing Baldwin v. Reese, 541 U.S. 27, 29 (2004); see also 28 U.S.C. § 2254(b)(1) (“An application for a writ of habeas corpus . . . shall not be granted unless it appears that the applicant has exhausted the remedies available in the courts of the State”)).

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Maiden v. Payne, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maiden-v-payne-ared-2020.