McKnight v. NH DOC

2006 DNH 081
CourtDistrict Court, D. New Hampshire
DecidedJuly 11, 2006
Docket05-CV-161-SM
StatusPublished

This text of 2006 DNH 081 (McKnight v. NH DOC) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McKnight v. NH DOC, 2006 DNH 081 (D.N.H. 2006).

Opinion

McKnight v . NH DOC 05-CV-161-SM 07/11/06 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Walter M . McKnight, Plaintiff

v. Civil N o . 05-cv-161-SM Opinion N o . 2006 DNH 081 Commissioner, New Hampshire Department of Corrections, and Warden, Northern N.H. Correctional Facility, Defendants

O R D E R

Walter McKnight, an inmate at the Northern New Hampshire

Correctional Facility, brings this petition seeking habeas corpus

relief. See 28 U.S.C. § 2254. In short, he claims to have fully

served concurrent sentences of 5 to 10 years in prison and says

prison officials are unlawfully refusing to release him from

their custody. Defendants, on the other hand, assert that

McKnight is still serving time on his second term of

imprisonment, which is consecutive t o , not concurrent with, the

sentence he has already served.

In support of his petition, McKnight seems to advance two

claims. First, he says defendants have wrongfully detained him

beyond his maximum release date, in violation of his

constitutionally protected liberty interests. Next, he claims that if his release date has not yet arrived, his right to due

process was violated when the state trial court sentenced him to

consecutive terms of imprisonment without adequately explaining

that fact to him. Defendants move for summary judgment, saying

there are no genuinely disputed material facts and, as a matter

of law, McKnight’s claims fail. McKnight has not filed an

objection.

Standard of Review

I. Summary Judgment.

When ruling on a party’s motion for summary judgment, the

court must “view the entire record in the light most hospitable

to the party opposing summary judgment, indulging all reasonable

inferences in that party’s favor.” Griggs-Ryan v . Smith, 904

F.2d 1 1 2 , 115 (1st Cir. 1990). Summary judgment is appropriate

when the record reveals “no genuine issue as to any material fact

and . . . the moving party is entitled to a judgment as a matter

of law.” Fed. R. Civ. P. 56(c). In this context, “a fact is

‘material’ if it potentially affects the outcome of the suit and

a dispute over it is ‘genuine’ if the parties’ positions on the

issue are supported by conflicting evidence.” Int’l Ass’n of

Machinists & Aerospace Workers v . Winship Green Nursing Ctr., 103

F.3d 196, 199-200 (1st Cir. 1996) (citations omitted).

2 Here, because McKnight failed to object to defendants’

motion for summary judgment, the court will take as admitted the

factual statements recited in defendants’ motion, as supported by

the attached exhibits. See Local Rule 7.2(b)(2) (“All properly

supported material facts set forth in the moving party’s factual

statement shall be deemed admitted unless properly opposed by the

adverse party.”). See also McCrory v . Spigel, 260 F.3d 2 7 , 31

(1st Cir. 2001) (“Although we view the evidence in the light most

favorable to the nonmovant, as to any essential factual element

of its claim on which the nonmovant would bear the burden of

proof at trial, its failure to come forward with sufficient

evidence to generate a trialworthy issue warrants summary

judgment to the moving party.”) (citations and internal quotation

marks omitted).

II. Habeas Corpus.

Since passage of the Anti-Terrorism and Effective Death

Penalty Act of 1996 (“AEDPA”), 28 U.S.C. § 2254(d), the power to

grant federal habeas relief to a state prisoner with respect to

claims adjudicated on the merits in state court has been

substantially limited. A federal court may not disturb a state

conviction unless the state court’s resolution of the issues

before it “resulted in a decision that was contrary t o , or

3 involved an unreasonable application o f , clearly established

Federal law, as determined by the Supreme Court of the United

States.” 28 U.S.C. § 2254(d)(1). See also Williams v . Taylor,

529 U.S. 362 (2000). Alternatively, habeas relief may be granted

if the state court’s adjudication “resulted in a decision that

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)(2).

Here, McKnight challenges his continuing incarceration on

grounds that the state habeas court erroneously concluded that:

(1) the trial court sentenced him to serve two consecutive,

rather than concurrent, terms of imprisonment of 5 to 10 years;

and (2) he was fully and fairly notified of those sentences and,

therefore, was not deprived of his right to due process. S o , to

prevail on either claim, McKnight must demonstrate that the state

habeas court’s rejection of his petition was based on an

unreasonable determination of the relevant facts, based on the

record then before i t . See 28 U.S.C. § 2254(d)(2). Moreover,

because the federal habeas corpus statute provides that “a

determination of a factual issue made by a State court shall be

presumed to be correct,” 28 U.S.C. § 2254(e), McKnight bears the

4 burden of “rebutting the presumption of correctness by clear and

convincing evidence,” id.1

Background

In March of 1994, McKnight was convicted of three counts of

aggravated felonious sexual assault (state court docket numbers

93-S-1091, 1092, and 1094), as well as two counts of felonious

sexual assault. In June of that year, the trial court sentenced

McKnight as follows:

1. Case number 93-S-1091: not more than 10 years, nor less than 5 years, stand committed, with pretrial confinement credit of 72 days;

2. Case number 93-S-1094: not more than 10 years, nor less than 5 years, consecutive to the sentence imposed in case n o . 93-S-1091

1 Arguably, McKnight’s second claim - that he was denied due process - is based on his assertion that the state habeas court resolved the issue in a manner that was contrary t o , or involved an unreasonable application o f , federal law. But, McKnight did not clearly articulate that claim until he filed his motion for reconsideration (which the court denied without comment). Accordingly, the state habeas court never specifically addressed the due process claim. But, in denying McKnight’s motion to reconsider, the court necessarily concluded that McKnight was not denied due process because: (1) the trial court’s sentencing sheets and forms revealed that the court had plainly sentenced McKnight to two consecutive, rather than concurrent, terms of imprisonment; and (2) McKnight failed to point to any evidence that might suggest the trial court neglected to fully apprise him of the consecutive nature of the sentences - both of which are findings of fact.

5 (i.e., commencing upon McKnight’s having served the sentence imposed in case n o . 93-S- 1091); and

3.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Edmund Mann and Beverly Mann v. United States
904 F.2d 1 (Second Circuit, 1990)
United States v. Miller
20 F.3d 926 (Eighth Circuit, 1994)
Riley v. Whittiker
49 N.H. 145 (Supreme Court of New Hampshire, 1869)
State v. Rau
523 A.2d 98 (Supreme Court of New Hampshire, 1987)
Basbanes' Case
676 A.2d 93 (Supreme Court of New Hampshire, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
2006 DNH 081, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcknight-v-nh-doc-nhd-2006.