Marchak v. Warden, Richland Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedOctober 17, 2023
Docket2:22-cv-04001
StatusUnknown

This text of Marchak v. Warden, Richland Correctional Institution (Marchak v. Warden, Richland 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
Marchak v. Warden, Richland Correctional Institution, (S.D. Ohio 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS MICHAEL MARCHAK, JR., Petitioner, : Case No. 2:22-cv-04001

-vs - District Judge Michael H. Watson Magistrate Judge Michael R. Merz WARDEN, Richland Correctional Institution, : Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case, brought pro se by Petitioner Michael Marchak, Jr., is before the Court for decision on the merits. Relevant pleadings are the Petition (ECF No. 3), the State Court Record (ECF No. 7), the Return of Writ (ECF No. 8), and Petitioner’s Traverse (ECF No. 13). The Magistrate Judge reference in the case has recently been transferred to the undersigned to help balance the Magistrate Judge workload in the District (ECF No. 14). Final decision of the case remains with District Judge Watson.

Litigation History

On August 27, 2019, the Morrow County grand jury indicted Petitioner on charges of aggravated vehicular assault (victim Ohio State Highway Patrol Trooper Phillips), in violation of Ohio Rev. Code § 2903.08(A)(1)(a), a felony of the second degree because Petitioner was driving under suspension at the time of the offense (count one); aggravated vehicular assault (victim Kojo Tsiboe), a violation of Ohio Rev. Code § 2903.08(A)(1)(a), a felony of the second degree for the same reason as count one (count two); one count of receiving stolen property in violation of Ohio Rev. Code. § 2913.51 (count three), one count of operating a motor vehicle while under the influence of alcohol or a drug of abuse in violation of Ohio Revised Code § §4511.19(A)(1)(a)(count four);one count of

operating a motor vehicle while under the influence of alcohol or a drug of abuse (methamphetamine), in violation of Ohio Revised Code §4511.19(A)(1)(a)(count five); one count of driving on a suspended license in violation of Ohio Rev. Code §4510.11(A)(count six), and one count of driving on a license suspended under the financial responsibility law in violation of Ohio Revised Code §4510.16(A)(count seven). (Indictment, State Court Record, ECF No. 7, Ex. 1). In April, 2021, the State and Marchak reached a plea agreement in which Petitioner agreed to plead guilty to two counts of aggravated vehicular assault, as amended from a felony of the second degree to a felony of the third degree by eliminating the reference to the offense’s having occurred while the Marchak was driving under suspension, one count of receiving stolen property, and one count of driving under suspension. The parties agreed to jointly recommend an aggregate

prison term of eight years and the state agreed to dismiss Counts four, five, and seven (Plea Agreement, State Court Record, ECF No. 7, Ex. 3 and 4). The trial court sentenced Petitioner as recommended in the plea agreement, but he appealed. Appointed appellate counsel moved to withdraw under Anders v. California, 386 U.S. 738 (1967). Petitioner filed a supplemental brief pro se raising two claims of ineffective assistance of trial counsel. Id. at Ex. 11. The Fifth District Court of Appeals affirmed the conviction. State v. Marchak, 2022-Ohio- 2611 (5th Dist. Jul. 29, 2022). Petitioner appealed, but the Supreme Court of Ohio declined to exercise jurisdiction (Entry, State Court Record, ECF No. 7, Ex. 18). On November 4, 2022, Marchak filed his Petition in this case, pleading the following Grounds for Relief: Ground One: Trial counsel’s performance was deficient in violation of Marchak's Sixth Amendment right to the U.S. Constitution.

Supporting Facts: Marchak's substantial due process rights were violated when he was denied effective assistance of trial counsel because trial counsel failed to properly advise him not [to] plead guilty to aggravated vehicular assault relating to the good samaritan, and failed to raise and argue the matter before the trial court, as an "attenuating chain of events severing causation, making the proper offense a third degree misdemeanor "negligent assault", in violation of his sixth amendment right to the U.S. Constitution.

Ground Two: Trial counsel's performance was deficient in violation of Marchak's Fifth and Sixth Amendment right to the U.S. Constitution.

Supporting Facts: Marchak's contends his trial counsel was ineffective in failing to raise the issue that the two counts of aggravated vehicular assault were allied offenses of similar import which should have merged for purposes of sentencing. Specifically, appellant contends he was fully incapacitated when the Good Samaritan stopped to assist the trooper and thus, appellant did not commit a separate act, and the offenses must merge because both were committed with the same conduct.

Ground Three: Marchak's guilty plea to count 2, aggravated vehicular assault, was neither intelligent nor voluntary under Alford v. North Carolina because there was no factual basis to support a finding that he was operating his vehicle when the Good Samaritan was injured.

Supporting Facts: Marchak argues that in Count Two- aggravated vehicular assault on Mr. Kojo Tsiboe”, Mr. Tsiboe had full knowledge of an open and visible condition; he appreciated the dangers incident thereto and voluntarily acted by helping the injured victim, he assumed the risk of the attendant dangers.

Ground Four: Marchak's plea of guilty on Count Two was not entered knowingly, willingly, and voluntarily in violation of the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Supporting Facts: When an injury occurred as a later result of the Appellant's negligence was separated from the immediate and "proximate cause", "intervening causation" mitigates the Appellant's criminal liability, and Due Process precludes conviction and sentence for "Aggravated Vehicular Assault", and requires a conviction and sentence for "negligent assault".

(Petition, ECF No. 3).

Analysis

Ground One: Ineffective Assistance of Trial Counsel: Intervening Cause

In his First Ground for Relief, Petitioner asserts his trial attorney provided ineffective assistance of trial counsel when advising him to plead guilty to the charge of aggravated vehicular assault as a third degree felony with respect to victim Kojo Tsiboe because there was an intervening cause between Marchak’s negligence and the injuries Mr. Tsiboe suffered, to wit, Mr. Tsiboe’s voluntary act of exposing himself to the risk of the injury he suffered when rescuing Trooper Phillips. Respondent concedes this claim is preserved for merits consideration in this Court, but asserts we must defer to the decision of the Ohio Fifth District Court of Appeals rejecting this claim on the merits (Return, ECF No. 8, PageID 402-05). Petitioner replies that the facts underlying the second count of the indictment would have supported a conviction for negligent assault. He then contends Mr. Tsiboe voluntarily assumed the risks of injury by intervening to rescue Trooper Phillips, thereby breaking the chain of causation and preventing him from being liable for felony assault (Traverse, ECF No. 13, PageID 455-62). In relevant part the Fifth District Court of Appeals made the following findings of fact and reached the following conclusions of law: {¶2} A state trooper with the Ohio Highway Patrol was responding to a report of an intoxicated motorist driving on Interstate 71. The trooper was struck head-on by the intoxicated motorist, appellant, who was driving the wrong way on the highway.

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Related

Anders v. California
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Marchak v. Warden, Richland Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marchak-v-warden-richland-correctional-institution-ohsd-2023.