Montgomery v. Cotton

CourtCourt of Appeals for the Tenth Circuit
DecidedMarch 26, 2026
Docket25-5090
StatusUnpublished

This text of Montgomery v. Cotton (Montgomery v. Cotton) 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
Montgomery v. Cotton, (10th Cir. 2026).

Opinion

Appellate Case: 25-5090 Document: 15-1 Date Filed: 03/26/2026 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT March 26, 2026 _________________________________ Christopher M. Wolpert Clerk of Court JAMES EDWARD MONTGOMERY,

Petitioner - Appellant,

v. No. 25-5090 (D.C. No. 4:17-CV-00445-CVE-JFJ) JAMES COTTON, Interim Warden, (N.D. Okla.)

Respondent - Appellee. _________________________________

ORDER DENYING CERTIFICATE OF APPEALABILITY * _________________________________

Before TYMKOVICH, BALDOCK, and MORITZ, Circuit Judges. _________________________________

James Edward Montgomery, an Oklahoma prisoner proceeding pro se, 1 seeks a

certificate of appealability (COA) to appeal from the district court’s denial of his

28 U.S.C. § 2254 habeas application. We deny a COA and dismiss this matter.

I. BACKGROUND

In a bifurcated trial, an Oklahoma state jury first convicted Montgomery of

maiming, resisting an officer, and public intoxication. During the second stage of trial,

* This order is not binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel.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.

Because Montgomery represents himself, we construe his filings liberally, but 1

we do not act as his advocate. See Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). Appellate Case: 25-5090 Document: 15-1 Date Filed: 03/26/2026 Page: 2

the jury found that Montgomery had two prior felony convictions and recommended the

following sentences: a sixty-year prison term for maiming, a one-year prison term for

resisting an officer, and a thirty-day jail term for public intoxication. The trial court

sentenced Montgomery according to the jury’s recommendations. The Oklahoma Court

of Criminal Appeals (OCCA) affirmed his convictions and sentences. He then filed a

§ 2254 habeas application in federal court, claiming insufficient evidence, a due process

violation, ineffective assistance of trial counsel, prosecutorial misconduct, and improper

response to a jury question by the trial court. The district court denied habeas relief.

Montgomery now seeks a COA to appeal the district court’s rejection of his habeas

application.

II. DISCUSSION

Before he can appeal, Montgomery must obtain a COA. See 28 U.S.C.

§ 2253(c)(1)(A). To do so, he must make “a substantial showing of the denial of a

constitutional right.” Id. § 2253(c)(2). Because the district court denied his claims on the

merits, Montgomery “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 may grant habeas relief

on that claim only if 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,” or “was based on an unreasonable determination of

2 Appellate Case: 25-5090 Document: 15-1 Date Filed: 03/26/2026 Page: 3

the facts in light of the evidence presented in the State court proceeding.” 28 U.S.C.

§ 2254(d)(1), (2). When reviewing COA requests, we give “deferential treatment [to]

state court decisions.” Dockins v. Hines, 374 F.3d 935, 938 (10th Cir. 2004).

A state-court decision is contrary to clearly established federal law if the state

court (1) “applies a rule that contradicts the governing law set forth in Supreme Court

cases,” or (2) “confronts a set of facts that are materially indistinguishable from a

decision of the Supreme Court and nevertheless arrives at a result different from that

precedent.” House v. Hatch, 527 F.3d 1010, 1018 (10th Cir. 2008) (brackets and internal

quotation marks omitted). A state-court decision involves an unreasonable application of

clearly established federal law “when it identifies the correct governing legal rule from

Supreme Court cases, but unreasonably applies it to the facts.” Id.

Montgomery requests a COA on his sufficiency-of-the-evidence claim, his

ineffective assistance of counsel claim, and his claim that the trial court responded

improperly to a jury question.

A. Sufficiency of the Evidence

Montgomery argues the prosecution failed to prove beyond a reasonable doubt

that he committed the crime of maiming. For a sufficiency-of-the-evidence claim, “the

relevant question is whether, 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.” Jackson v. Virginia, 443 U.S. 307, 319 (1979). Under

Oklahoma law, “[e]very person who, with premeditated design to injure another, inflicts

upon his person any injury which disfigures his personal appearance or disables any

3 Appellate Case: 25-5090 Document: 15-1 Date Filed: 03/26/2026 Page: 4

member or organ of his body or seriously diminishes his physical vigor, is guilty of

maiming.” Okla. Stat. tit. 21, § 751.

Applying Jackson, the OCCA determined the prosecution provided sufficient

evidence at trial for the jury to convict Montgomery of maiming. Montgomery argues

the evidence was insufficient to establish that he had the intent to injure the victim. But

the evidence included testimony from an ophthalmologist who treated the victim that the

victim’s eye injury was consistent with intentional gouging, not an accidental jab.

The district court determined that the OCCA’s rejection of Montgomery’s

sufficiency-of-the-evidence claim was not an unreasonable application of Jackson or

based on an unreasonable determination of the facts presented in state court. We afford

deference to the OCCA’s decision, see Dockins, 374 F.3d at 938, and we conclude no

reasonable jurist would debate the district court’s rejection of Montgomery’s

sufficiency-of-the-evidence claim.

B. Ineffective Assistance of Counsel

Strickland v. Washington, 466 U.S. 668 (1984), governs ineffective-assistance

claims. Under Strickland, the applicant must show (1) “that counsel’s performance was

deficient” and (2) “that the deficient performance prejudiced the defense.” Id. at 687.

The first prong requires an applicant to show “that counsel made errors so serious that

counsel was not functioning as the ‘counsel’ guaranteed . . . by the Sixth Amendment.”

Id.

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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)
Dockins v. Hines
374 F.3d 935 (Tenth Circuit, 2004)
House v. Hatch
527 F.3d 1010 (Tenth Circuit, 2008)
Hall v. Bellmon
935 F.2d 1106 (Tenth Circuit, 1991)
United States v. Mark Carter
973 F.2d 1509 (Tenth Circuit, 1992)
Harris v. Sharp
941 F.3d 962 (Tenth Circuit, 2019)

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