Mead v. Harding

CourtCourt of Appeals for the Tenth Circuit
DecidedFebruary 4, 2025
Docket24-7031
StatusUnpublished

This text of Mead v. Harding (Mead v. Harding) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mead v. Harding, (10th Cir. 2025).

Opinion

Appellate Case: 24-7031 Document: 23-1 Date Filed: 02/04/2025 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT February 4, 2025 _________________________________ Christopher M. Wolpert Clerk of Court WILLIAM CLAUDE MEAD,

Petitioner - Appellant,

v. No. 24-7031 (D.C. No. 6:19-CV-00426-JFH-DES) RANDY HARDING, Warden, (E.D. Okla.)

Respondent - Appellee. _________________________________

ORDER DENYING CERTIFICATE OF APPEALABILITY * _________________________________

Before MATHESON, Circuit Judge, LUCERO, Senior Circuit Judge, and PHILLIPS, Circuit Judge. _________________________________

William Claude Mead, a state prisoner proceeding pro se, seeks a certificate of

appealability (“COA”) to challenge the district court’s denial of his 28 U.S.C. § 2254

habeas petition. See 28 U.S.C. § 2253(c)(1)(A) (requiring a COA to appeal an order

* This order is not binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 24-7031 Document: 23-1 Date Filed: 02/04/2025 Page: 2

denying a § 2254 petition). Exercising jurisdiction under 28 U.S.C. §§ 1291 and 2253(a),

we deny a COA and dismiss this matter. 1

I. BACKGROUND

After a bench trial, Mr. Mead was convicted in state court of one count of lewd

molestation and two counts of sodomy of a minor. The trial court sentenced him to 20

years in prison on each count, to be served concurrently. The Oklahoma Court of

Criminal Appeals (“OCCA”) affirmed his convictions and sentence. The trial court

denied Mr. Mead’s application for state post-conviction relief, and the OCCA affirmed.

Mr. Mead then filed a § 2254 petition in federal court, raising 10 claims. The district

court denied the petition. Mr. Mead now seeks a COA to appeal the district court’s

rejection of his sufficiency-of-the-evidence claim (Ground One), three ineffective

assistance of appellate counsel claims (Grounds Two, Five, and Seven), 2 and his

cumulative error claim (Ground Ten).

II. DISCUSSION

A. Legal Background

COA Requirement and Standard of Review

Mr. Mead must obtain a COA for this court to review the district court’s denial of

his § 2254 application. See 28 U.S.C. § 2253(c)(1)(A). To do so, he must make “a

1 Because Mr. Mead appears pro se, “we liberally construe his filings, but we will not act as his advocate.” James v. Wadas, 724 F.3d 1312, 1315 (10th Cir. 2013). 2 In resolving Grounds Two through Eight in the habeas petition, the district court agreed with the State it was unclear whether Mr. Mead intended to raise ineffective assistance of trial counsel or of appellate counsel claims. The district court considered 2 Appellate Case: 24-7031 Document: 23-1 Date Filed: 02/04/2025 Page: 3

substantial showing of the denial of a constitutional right.” Id. § 2253(c)(2). For claims

denied on the merits, he “must demonstrate that reasonable jurists would find the district

court’s assessment of the constitutional claims debatable or wrong.” Slack v. McDaniel,

529 U.S. 473, 484 (2000).

Under the Antiterrorism and Effective Death Penalty Act (“AEDPA”), when a

state court has adjudicated the merits of a claim, a federal district court cannot grant

habeas relief on that claim unless the state court’s decision “was contrary to, or involved

an unreasonable application of, clearly established Federal law, as determined by the

Supreme Court of the United States,” 28 U.S.C. § 2254(d)(1), or “was based on an

unreasonable determination of the facts in light of the evidence presented in the State

court proceeding,” id. § 2254(d)(2). Under these circumstances, we thus must determine

as part of our COA analysis whether reasonable jurists could debate the court’s decision

in light of AEDPA deference to the state court. See Miller-El v. Cockrell, 537 U.S. 322,

336 (2003). But when the state court did not address the merits of a claim, AEDPA

deference does not apply because “federal-court deference to the state court’s decision is

appropriate only on claims ‘adjudicated on the merits’ by the state court.” Black v.

Workman, 682 F.3d 880, 893 (10th Cir. 2012) (quoting 28 U.S.C. § 2254(d)).

both types. It determined the trial counsel claims were procedurally barred, but reached the merits of the appellate counsel claims. In his COA application, Mr. Mead challenges only the district court’s resolution of his appellate counsel claims.

3 Appellate Case: 24-7031 Document: 23-1 Date Filed: 02/04/2025 Page: 4

Sufficiency of the Evidence

The controlling Supreme Court authority regarding sufficiency of the evidence is

Jackson v. Virginia, 443 U.S. 307 (1979). Under Jackson, the evidence is sufficient

when a court determines, “after viewing the evidence in the light most favorable to the

prosecution, any rational trier of fact could have found the essential elements of the crime

beyond a reasonable doubt.” Id. at 319. “Review of sufficiency of the evidence under

AEDPA adds an additional degree of deference, and the question becomes whether the

OCCA’s conclusion that the evidence was sufficient constituted an unreasonable

application of the Jackson standard.” Simpson v. Carpenter, 912 F.3d 542, 592

(10th Cir. 2018) (quotations omitted); see also Coleman v. Johnson, 566 U.S. 650, 651

(2012) (per curiam) (“Jackson claims face a high bar in federal habeas proceedings

because they are subject to two layers of judicial deference.”). We “may not . . . consider

the credibility of witnesses” and “must accept the jury’s resolution of the evidence as

long as it is within the bounds of reason.” Messer v. Roberts, 74 F.3d 1009, 1013

(10th Cir. 1996) (quotations omitted).

Ineffective Assistance of Counsel

We analyze ineffective assistance of counsel under the two-prong test established

in Strickland v. Washington, 466 U.S. 668 (1984). A habeas petitioner must show

(1) counsel’s performance was deficient and (2) that the deficient performance prejudiced

the defense.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
United States v. Orange
447 F.3d 792 (Tenth Circuit, 2006)
Jerome Messer v. Raymond Roberts
74 F.3d 1009 (Tenth Circuit, 1996)
Coleman v. Johnson
132 S. Ct. 2060 (Supreme Court, 2012)
Black v. Workman
682 F.3d 880 (Tenth Circuit, 2012)
James v. Wadas
724 F.3d 1312 (Tenth Circuit, 2013)
Owens v. Trammell
792 F.3d 1234 (Tenth Circuit, 2015)
Simpson v. Carpenter
912 F.3d 542 (Tenth Circuit, 2018)

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