Martin-Andrade v. Benzel

CourtDistrict Court, E.D. Wisconsin
DecidedMarch 14, 2025
Docket2:23-cv-01722
StatusUnknown

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

Bluebook
Martin-Andrade v. Benzel, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

HECTOR M. MARTIN-ANDRADE,

Petitioner, Case No. 23-CV-1722-JPS-JPS v.

DAN CROMWELL,1 ORDER

Respondent.

1. INTRODUCTION Petitioner Hector M. Martin-Andrade (“Petitioner”), who is currently incarcerated at Dodge Correctional Institution, petitions the Court for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. ECF No. 1. The petition purports to assert eight grounds for relief, which Petitioner enumerates as follows: • Ground One: “Ineffective Assistance of Postconviction Counsel ([Attorney Robert T.] Ruth) in omitting, without reasonable justification, an obvious, clearly stronger, and winning issue respecting prosecutorial misconduct due to a Berger [v. United States, 295 U.S. 78 (1935)] violation when the Prosecutor threw the weight of his own credibility as a representative of the Government behind

1The Court has substituted Dan Cromwell as the proper Respondent as the current Warden of Dodge Correctional Institution. See Fed. R. Civ. P. 25(d); see also Rule 2(a), RULES GOVERNING SECTION 2254 CASES IN THE UNITED STATES DISTRICT COURTS (“If the petitioner is currently in custody under a state court judgment, the petition must name as respondent the state officer who has custody.”). his personal opinions during his closing argument to the jury.” ECF No. 1 at 6; • Ground Two: “Ineffective Assistance of Postconviction Counsel (Ruth) in omitting, without reasonable justification, an obvious, clearly stronger, and winning issue respecting ineffective assistance of trial counsel in failing to object at trial to the legally improper statements made by the prosecutor during his closing argument to the jury.” Id. at 7; • Ground Three: “Ineffective assistance of postconviction counsel (Ruth) in omitting[] stronger[] and winning issue respecting ineffective assistance of trial counsel in failing to introduce [the victim’s] normal medical/SANE exam (and request for an order compelling copies of the medical/SANE records).” Id. at 8; • Ground Four: “Postconviction counsel (Ruth) provided ineffective assistance by inadequately and improperly raising the issue regarding trial counsel’s ineffective assistance due to trial counsel’s failure to move to exclude the testimony of the state’s expert witness ([Amanda] Didier), where attorney Ruth unjustifiably raised the issue ‘in the alternative’ and wrongly asserted that ‘counsel adequately objected to the tardy and inadequate disclosure of discovery.’” Id. at 9; • Ground Five: “Ineffective assistance of postconviction counsel (Ruth) in omitting, without reasonable justification, an obvious, clearly stronger, and winning issue respecting ineffective assistance of trial counsel in failing to make a timely objection at the pre-trial conference to the state’s failure to produce discovery, and in failing to conduct a proper investigation into the State’s expert (Didier).” Id. at 10; • Ground Six: “Prosecutorial misconduct attributable to the prosecutor’s repeated reference to the alleged victim’s lost sexual innocence at the hand of the Defendant (Plain error respecting Constitutional violation).” Id. at 11; • Count Seven: “Petitioner’s Sixth Amendment right to counsel and Fourteenth Amendment right to Due Process under the U.S. Constitution were violated when the trial court denied Petitioner’s motion to adjourn.” Id. at 12; and • Ground Eight: “Petitioner was deprived of his Sixth Amendment right to the effective assistance of trial counsel. While the motion to adjourn had the potential of curing the late discovery, the lack of a witness list, and the incomplete expert summary (because it would have permitted defense counsel time to prepare for Petitioner’s defense, counsel should have moved to exclude any witness not listed and should have objected to the areas of Didier’s testimony where she exceeded the scope of the expert summary. Additionally, trial counsel was ineffective in failing to object or move for a mistrial when the prosecutor repeatedly referenced [the victim’s] alleged loss of innocence.” Id. at 13. Respondent Dan Cromwell (“Respondent”) moves to dismiss the petition on the basis that the grounds within it are either unexhausted or procedurally defaulted. ECF No. 8. For the reasons discussed below, the Court will grant in part and deny in part the motion to dismiss. 2. BACKGROUND 2.1 Trial and Sentencing In November 2015, a jury found Petitioner guilty of a charge of first- degree child sexual assault (intercourse with person under 12). State of Wisconsin v. Hector M. Martin-Andrade, 2015CF000366 (Milwaukee Cnty. Cir. Ct. 2015), available at https://wcca.wicourts.gov/caseDetail.html?caseNo=2015CF000366&county No=40&index=0&mode=details. The circuit court sentenced him to twenty- five years of imprisonment to be followed by a fifteen-year term of extended supervision. Id. At trial and sentencing, Petitioner was represented by Attorney Robert R. Ledesma (“Attorney Ledesma”). Id. 2.2 Motion for New Trial In March 2018, Petitioner moved the circuit court for a new trial through Attorney Robert T. Ruth (“Attorney Ruth”). ECF No. 9-7 at 20 (also requesting an evidentiary hearing with respect to claims of ineffective assistance of counsel). In the motion for a new trial, Attorney Ruth asserted the following grounds: • “The trial court erred when it denied trial counsel’s November 23, 2015[] motion to adjourn the trial.” Id. at 1; • “The trial court erred when it permitted the state’s expert witness [Didier] to testify beyond the scope of the expert summary provided by the state.” Id. at 7; • “The prosecutor committed plain error when he repeatedly argued to the jury that this case was about the alleged victim’s lost sexual innocence at the hand of the defendant.” Id. at 9; • “Trial counsel failed to object to the state’s lack of a witness list and failed to move to exclude the witnesses not listed on a witness list by the state.” Id. at 14; • “Trial counsel failed to seek the exclusion of witnesses Amanda Didier and [the victim] on the ground that the state failed to provide their written or recorded statements within a reasonable time before trial.” Id.; • “Trial counsel failed to move to exclude expert testimony on subjects not set forth in the expert summary turned over within a reasonable time before trial.” Id.; and • “Trial counsel failed to object to the prosecutor’s repeated claims that this case was about the alleged victim’s lost innocence at the hand of the defendant.” Id. In June 2018, the circuit court denied the motion in a short order. ECF No. 9-8. The circuit court concluded that the claims were “conclusory” and that “[t]he motion [wa]s insufficient to warrant a hearing.” Id. at 2 (citing Nelson v. State, 195 N.W.2d 629, 633 (Wis. 1972)). The circuit court rejected Petitioner’s complaints regarding the prosecutor’s closing argument, seemingly on the merits. Id. at 3 (“The court is not persuaded that the State’s comments caused the defendant to receive an unfair trial.”). The circuit court also rejected Petitioner’s ineffective assistance of trial counsel arguments, also seemingly on the merits. Id. at 4 (“The court finds nothing demonstrating that the defendant was prejudiced by counsel’s actions with respect to any of the allegations of ineffective assistance. There is not a reasonable probability that [the circuit court] would have sustained any of the defendant’s objections, and the court is not persuaded that [the circuit court] would have granted a mistrial based on the comments made by the State in closing argument.”).

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Bluebook (online)
Martin-Andrade v. Benzel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-andrade-v-benzel-wied-2025.