Melendez v. Neven

CourtDistrict Court, D. Nevada
DecidedSeptember 23, 2019
Docket2:16-cv-01003
StatusUnknown

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

Bluebook
Melendez v. Neven, (D. Nev. 2019).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Mauricio I. Melendez, Case No.: 2:16-cv-01003-JAD-DJA 4 Petitioner 5 v. Order Denying Habeas Petition and Certificate of Appealability 6 Brian Williams,et al., [ECF No. 18] 7 Respondents 8 9 Nevada state prisoner Mauricio I. Melendezbrings this habeas petition to challenge his 10 first-degree-murder conviction for the shooting death of his wife.1 Melendez claims that his 11 prosecution was plagued by ineffective assistance of counsel and prosecutorial misconduct. But, 12 because I find that Melendez has not shown any basis for habeas relief, I deny the petition, 13 decline a certificate of appeal, and close this case. 14 BACKGROUND2 15 In August 2008, Melendez shot his wife, Chennel, in the forehead while she was sitting at 16 the couple’s kitchen table. Melendez admittedto police that he shot and killed Chennel, but he 17 claimedthat he did so unintentionally and that he did not know the gun was loaded. TheState 18 presented evidence at trial that, rather than immediately calling 911 or seeking other help, 19 Melendez wrappedChennel’s body in a blanket, transportedit from the kitchen table to the 20 couch, and cleanedup blood in the kitchen. He alsotook multiple photographs of Chennel’s 21 bodyin the hours after her death. 22 1 ECF No. 18. 23 2 This background is derived from the exhibits filed under ECF Nos.19–21 and this court’s own docket. 1 After a five-day trial in the EighthJudicial District Court, Clark County, Nevada, in July 2 2009,thejury found Melendez guilty of first-degree murder with the use of a deadly weapon. 3 The court sentenced Melendez to two consecutive terms of life with the possibility of parole after 4 twenty years. Melendez appealed. In July 2011, the Nevada Supreme Court affirmed the 5 conviction. In February 2012, Melendez filed a proper person state habeas petition in the state

6 district court. With the assistance of appointed counsel, he filed several supplemental petitions. 7 The state district court conducted an evidentiary hearing and granted the petition, concluding that 8 Melendez’s trial attorneys were ineffective in several respects, but the Nevada Supreme Court 9 reversed the lower court’s decision to grant relief. 10 On May 2, 2016, Melendez filed his proper person federal habeas petition. With the 11 assistance of appointed counsel, he filed a first amended petition on February 24, 2017. On 12 respondents’ motion, I dismissed claim 1E of the first amended petition as unexhaustedon 13 February 20, 2018, and Melendez then opted to abandon that claim. I now consider Melendez’s 14 remaining claims on theirmerits.

15 STANDARDS OF REVIEW 16 A. Legal standards 17 If a state court has adjudicated a habeas corpus claim on its merits, a federal district court 18 may only grant habeas relief with respect to that claim if the state court’s adjudication “resulted 19 in a decision that was contrary to, or involved an unreasonable application of, clearly established 20 Federal law, as determined by the Supreme Court of the United States” or “resulted in a decision 21 that was based on an unreasonable determination of the facts in light of the evidence presented in 22 the State court proceeding.”3 A state court acts contrary to clearly established federal law if it 23 3 28 U.S.C. § 2254(d). 1 applies a rule contradicting the relevant holdings or reaches a different conclusion on materially 2 indistinguishable facts.4 And a state court unreasonably applies clearly established federal law if 3 it engages in an objectively unreasonable application of the correct governing legal rule to the 4 facts at hand.5 Section 2254 does not, however, “require state courts to extend” Supreme Court 5 precedent “to a new context where it should apply” or “license federal courts to treat the failure

6 to do so as error.”6 The “objectively unreasonable” standard is difficult to satisfy;7 “even ‘clear 7 error’ will not suffice.”8 8 Habeas relief may only be granted if “there is no possibility [that] fairminded jurists could 9 disagree that the state court’s decision conflicts with [the Supreme Court’s] precedents.”9 As “a 10 condition for obtaining habeas relief,” a petitioner must show that the state-court decision “was 11 so lacking in justification that there was an error well understood and comprehended in existing 12 law beyond any possibility of fairminded disagreement.”10 “[S]o long as ‘fairminded jurists 13 could disagree’ on the correctness of the state court’s decision,” habeas relief under Section 14 2254(d) is precluded.11 The Antiterrorism and Effective Death Penalty Act (AEDPA) “thus

15 16 17 4 Price v. Vincent, 538 U.S. 634, 640 (2003). 18 5 White v. Woodall, 134 S. Ct. 1697, 1705–07 (2014). 6 White, 134 S. Ct. 1705–06. 19 7 Metrish v. Lancaster, 569 U.S. 351, 357–58 (2013). 20 8 Wood v. McDonald, 135 S. Ct. 1372, 1376 (2015) (per curiam) (citation omitted); see also Schriro v. Landrigan, 550 U.S. 465, 473 (2007) (“The question . . . is not whether a federal court 21 believes the state court’s determination was incorrect but whether that determination was unreasonable—a substantially higher threshold.”). 22 9 Harrington v. Richter, 562 U.S. 86, 102 (2011). 23 10 Id.at 103. 11 Id.at 101. 1 imposes a ‘highly deferential standard for evaluating state-court ruling,’ . . . and ‘demands that 2 state-court decisions be given the benefit of the doubt.’”12 3 If a federal district court finds that the state court committed an error under § 2254, the 4 district court must then review the claim de novo.13 The petitioner bears the burden of proving 5 by a preponderance of the evidence that he is entitled to habeas relief,14 but state-court factual

6 findings are presumed correct unless rebutted by clear and convincing evidence.15 7 DISCUSSION 8 A. Ground one: ineffective assistance of counsel 9 The claims in Ground Oneare all premised on allegations that Melendez was deprived of 10 his constitutional right to effective assistance of counsel. To demonstrate ineffective assistance 11 of counsel in violation of the Sixth and Fourteenth Amendments, a convicted defendant must 12 show that (1) counsel’s representation fell below an objective standard of reasonableness under 13 prevailing professional norms in light of all the circumstances of the particular case; and (2) it is 14 reasonably probable that, but for counsel’s errors, the result of the proceeding would have been

15 different.16 Melendez contends that his attorneys violated his constitutional right to effective 16 counsel in four separate—and compounding—ways. 17 18 19 20 12 Renico v. Lett, 559 U.S. 766, 773 (2010) (citations omitted). 13 Frantz v. Hazey, 533 F.3d 724, 735 (9th Cir. 2008) (en banc) (“[I]t is now clear both that we 21 may not grant habeas relief simply because of § 2254(d)(1) error and that, if there is such error, we must decide the habeas petition by considering de novo the constitutional issues raised.”). 22 14 Cullen v. Pinholster, 563 U.S. 170, 181 (2011). 23 15 28 U.S.C. § 2254(e)(1). 16 Strickland v. Washington, 466 U.S. 668, 687–94 (1984). 1 1. Claim 1A: failure to object to the State’s substituted coroner 2 In Ground 1A, Melendez alleges that he was deprived of effective assistance of counsel 3 because his trial counsel stipulated to the admission of an autopsy report prepared by a coroner 4 who did not testify at trial and allowed the State to present the testimony of a different coroner. 5 Chennel’s autopsy was conducted by Dr.

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Melendez v. Neven, Counsel Stack Legal Research, https://law.counselstack.com/opinion/melendez-v-neven-nvd-2019.