McInnis v. Woodson

CourtDistrict Court, E.D. Virginia
DecidedAugust 30, 2022
Docket3:20-cv-00561
StatusUnknown

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

Bluebook
McInnis v. Woodson, (E.D. Va. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division ANDARION LORENZO MCINNIS, Petitioner, v. Civil Action No. 3:20cv561 JOHN A. WOODSON, Respondent. MEMORANDUM OPINION Andarion Lorenzo McInnis, a Virginia state prisoner proceeding pro se, brings this petition pursuant to 28 U.S.C. § 2254 (“§ 2254 Petition,” ECF No. 6), challenging his convictions in the Circuit Court for the City of Virginia Beach (“Circuit Court”).! The respondent has moved to dismiss on the grounds that McInnis’s claims are procedurally barred or otherwise lack merit. (ECF No. 26.) McInnis has filed a response. (ECF No. 29.) The Motion to Dismiss, (ECF No. 26), will be GRANTED, the § 2254 Petition, (ECF No. 6), will be DENIED, and the action will be DISMISSED. I. PROCEDURAL HISTORY After a jury trial, McInnis was convicted of use of a firearm in the commission of a murder, use of a firearm in the commission of a robbery, robbery, and conspiracy to commit robbery. McInnis v. Commonwealth, No. 1937-17-1, 2018 WL 6313708, at *1 (Va. Ct. App. Dec. 4, 2018).? The Court of Appeals of Virginia affirmed his convictions. Id.

' McInnis submitted his § 2254 Petition on a form for filing a 28 U.S.C. § 2241 petition. (ECF No. 6.) Nevertheless, because he is challenging his state court convictions, the Court construes his submission as a § 2254 Petition. See Jn re Wright, 826 F.3d 774, 779 (4th Cir. 2016) (“[R]egardless of how they are styled, federal habeas petitions of prisoners who are ‘in custody pursuant the judgment of a State court’ should be treated ‘as applications under section 2254’... even if they challenge the execution of a state sentence.”) 2 The jury found McInnis not guilty of murder. Jd. at *1, n.1.

Thereafter, McInnis filed a petition for appeal in the Supreme Court of Virginia, in which he raised a single assignment of error: The Court of Appeals erred in finding that McInnis’s failure to raise Code Section 19.2-295.1 in its objection to the Admission of Facebook posts during the sentencing phase prevented the trial court from timely consideration of the objection and a proper ruling on its merits. Petition for Appeal, McInnis v. Commonwealth, No. 190073, at 4 (Va. filed Jan. 15, 2019). On July 17, 2019, the Supreme Court of Virginia refused McInnis’s petition for appeal. McInnis v. Commonwealth, No. 190073, at 1 (Va. July 17, 2019). The respondent maintains that McInnis did not file a state petition for a writ of habeas corpus. (See ECF No. 27, at 4.)° On July 22, 2020, the Court received McInnis’s original § 2254 petition in this action. (ECF No. 1.) On October 27, 2020, the Court received a second draft of McInnis’s § 2254 Petition that that the Court accepted for filing. (ECF No. 6.) McInnis raises four claims: Claim One: “(D]efense counsel failed to investigate what led to [McInnis’s] atrest, who was accusing [McInnis] of such crimes, and why [McInnis] was not given the opportunity to confront [his] accuser.” (id. at 6.) Claim Two: “False testimony and evidence used to obtain [MclInnis’s] conviction was unjust, thus violating [McInnis’s] Due Process [rights] granted to [him] by the Sth, 6th, and 14th Amendments of the United States [Constitution].” (/d. at 7.) Claim Three: “fI]f the false testimony and evidence were not used, no trier of facts could have found proof of guilt beyond a reasonable doubt, thus [MclInnis’s] Due Process rights would not have been violated.” (/d.) Claim Four: “[D]efense counsel failed to object to insufficiency of evidence in support of guilty verdict.” (/d. at 8.)

3 The Court employs that pagination assigned by the CM/ECF docketing system. The Court corrects the spelling, punctuation, and capitalization in quotations from the parties’ submissions.

II. PROCEDURAL DEFAULT Before a state prisoner can bring a § 2254 petition in federal district court, the prisoner must first have “exhausted the remedies available in the courts of the State.” 28 U.S.C. § 2254(b)(1)(A). State exhaustion “is rooted in considerations of federal-state comity,” and in a Congressional determination via federal habeas laws “that exhaustion of adequate state remedies will ‘best serve the policies of federalism.” Slavek v. Hinkle, 359 F. Supp. 2d 473, 479 (E.D. Va. 2005) (some internal quotation marks omitted) (quoting Preiser v. Rodriguez, 411 U.S. 475, 491-92, 492 n.10 (1973)). The purpose of exhaustion is “to give the State an initial opportunity to pass upon and correct alleged violations of its prisoners’ federal rights.” Picard v. Connor, 404 U.S. 270, 275 (1971) (internal quotation marks and citation omitted). Exhaustion has two aspects. First, a petitioner must utilize all available state remedies before the petitioner can apply for federal habeas relief. See O’Sullivan v, Boerckel, 526 U.S. 838, 844-48 (1999). As to whether a petitioner has used all available state remedies, the statute notes that a habeas petitioner “shall not be deemed to have exhausted the remedies available in the courts of the State . . . if he has the right under the law of the State to raise, by any available procedure, the question presented.” 28 U.S.C. § 2254(c). The second aspect of exhaustion requires a petitioner to have offered the state courts an adequate “opportunity” to address the constitutional claims advanced on federal habeas. Baldwin v. Reese, 541 U.S. 27, 29 (2004) (citing Duncan v. Henry, 513 U.S. 364, 365 (1995)). “To provide the State with the necessary ‘opportunity,’ the prisoner must ‘fairly present’ his claim in each appropriate state court (including a state supreme court with powers of discretionary review), thereby alerting that court to the federal nature of the claim.” Jd. (quoting Duncan, 513 U.S. at 365-66). Fair presentation demands that a petitioner present “both the operative facts and the controlling legal principles” to the state court. Longworth v. Ozmint, 377 F.3d 437, 448 (4th Cir.

2004) (internal quotation marks omitted) (quoting Baker v. Corcoran, 220 F.3d 276, 289 (4th Cir. 2000)). The burden of proving that a claim has been exhausted in accordance with a “state’s chosen procedural scheme” lies with the petitioner. Mallory v. Smith, 27 F.3d 991, 994-95 (4th Cir. 1994). “A distinct but related limit on the scope of federal habeas review is the doctrine of procedural default.” Breard v. Pruett, 134 F.3d 615, 619 (4th Cir. 1998). This doctrine provides that “[i]f a state court clearly and expressly bases its dismissal of a habeas petitioner’s claim on a state procedural rule, and that procedural rule provides an independent and adequate ground for the dismissal, the habeas petitioner has procedurally defaulted his federal habeas claim.” Jd. (citing Coleman v. Thompson, 501 U.S. 722, 731-32 (1991)). A federal habeas petitioner also procedurally defaults claims when he or she “fails to exhaust available state remedies and ‘the court to which the petitioner would be required to present his claims in order to meet the exhaustion requirement would now find the claims procedurally barred.’” Jd. (quoting Coleman, 501 U.S.

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Related

Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Johnson v. Louisiana
406 U.S. 356 (Supreme Court, 1972)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Marshall v. Lonberger
459 U.S. 422 (Supreme Court, 1983)
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Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Harris v. Reed
489 U.S. 255 (Supreme Court, 1989)
Lewis v. Jeffers
497 U.S. 764 (Supreme Court, 1990)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Ylst v. Nunnemaker
501 U.S. 797 (Supreme Court, 1991)
Estelle v. McGuire
502 U.S. 62 (Supreme Court, 1991)
Gray v. Netherland
518 U.S. 152 (Supreme Court, 1996)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Baldwin v. Reese
541 U.S. 27 (Supreme Court, 2004)
Crawford v. Washington
541 U.S. 36 (Supreme Court, 2004)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Schriro v. Landrigan
550 U.S. 465 (Supreme Court, 2007)
Giles v. California
554 U.S. 353 (Supreme Court, 2008)

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Bluebook (online)
McInnis v. Woodson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcinnis-v-woodson-vaed-2022.