Morga v. Daniels

District Court, D. Nevada·Decided June 19, 2024·No. 2:21-cv-01743·Unknown

Opinion

Ramon Morga, Case No. 2:21-cv-01743-APG-BNW

Petitioner v. Order

Jeremy Bean,1 et al., [ECF Nos. 4, 33, 36, 39] Respondents

Ramon Morga, a Nevada prisoner, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254. For the reasons that follow, I deny the petition. Morga alleges constitutional violations relating to a judgment of conviction in the Eighth Judicial District Court for Clark County, Nevada. He was found guilty of conspiracy to violate the Uniform Controlled Substances Act and trafficking in a controlled substance. ECF No. 4. Evidence presented at trial established the following facts. Working as an undercover detective with the Las Vegas Metropolitan Police Department (LVMPD), Anton Gross orchestrated four purchases of methamphetamine with a woman named Veronica Beltran. ECF No. 14-23 at 5-32. All four transactions took place in the parking lot of a Target store. Id. At the first two and the fourth purchases, Beltran herself appeared to sell the methamphetamine. Id. At the third transaction, Beltran asked to send her cousin in her place. Id. at 17-18. Gross assented, and moments later Morga entered Gross’s car. Id. at 19. After Morga gave Gross a shopping bag containing the narcotics, Gross handed Morga $1,600. Id. at 23-24. The substance in the

1 The current warden of High Desert State Prison, Jeremy Bean, is substituted for Charles Daniels as the primary respondent in this case. See Fed. R. Civ. P. 25(d). package Morga gave Gross tested positive for the presence of methamphetamine and weighed approximately 106 grams. Id. at 71-73. Morga did not appeal his conviction. He did, however, file a timely petition for post- conviction relief claiming that he received ineffective assistance of counsel (IAC) because his

trial counsel failed to preserve his right to a direct appeal. ECF No. 14-32. The state district court held an evidentiary hearing and denied relief. ECF Nos. 15-40. 15-41. Morga appealed. ECF No. 15-42. Finding that the state district court abused its discretion by denying Morga’s request for counsel, the Nevada Court of Appeals reversed and remanded the case “for appointment of counsel to assist Morga in the postconviction proceedings, including the filing of a supplemental petition.” ECF No. 15-8 at 3-4. Appointed counsel filed a supplemental petition claiming Morga’s factual innocence, alleging trial court error and insufficient evidence to sustain the conviction, and raising several more IAC claims. ECF No. 15-10. The district court held an evidentiary hearing and again denied relief. ECF Nos. 15-29, 15-37. Morga appealed. ECF No. 15-30. The Nevada Court of

Appeals affirmed the lower court’s denial of the IAC claims and concluded that the remaining claims were procedurally barred because they could have been raised on direct appeal. ECF No. 15-50. A few months after the conclusion of his state post-conviction proceedings, Morga initiated this federal habeas proceeding by submitting an initial petition (ECF No. 1-1), then shortly thereafter filing an amended petition (ECF No. 4). Respondents moved to dismiss several claims from the amended petition. ECF No. 13. I granted the motion in part, finding that Grounds 1, 2, and 3 failed to state a state cognizable claim for federal habeas relief. ECF No. 20. Respondents subsequently filed an answer addressing the merits of Morga’s remaining claims. ECF No. 27. Despite receiving two extensions of time, Morga did not file a reply within the time I provided him. ECF Nos. 29, 31. Beginning nearly two months after the time for filing his reply had expired, Morga began filing a series of documents requesting appointment of counsel and seeking to amend his petition. ECF Nos. 33, 34, 39, 40.

This action is governed by the Antiterrorism and Effective Death Penalty Act (AEDPA). The standard of review under AEDPA is set forth at 28 U.S.C. § 2254(d): An application for a writ of habeas corpus on behalf of a person in custody pursuant to the judgment of a State court shall not be granted with respect to any claim that was adjudicated on the merits in State court proceedings unless the adjudication of the claim – (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) 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.

A decision of a state court is “contrary to” clearly established federal law if the state court arrives at a conclusion opposite that reached by the Supreme Court on a question of law or decides a case differently than the Supreme Court has on a set of materially indistinguishable facts. Emil v. Taylor, 529 U.S. 362, 405-06 (2000). An “unreasonable application” occurs when “a state-court decision unreasonably applies the law of [the Supreme Court] to the facts of a prisoner’s case.” Id. at 409. “[A] federal habeas court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly.” Id. at 411. “A federal court’s collateral review of a state-court decision must be consistent with the respect due state courts in our federal system.” Miller-El v. Cockrell, 537 U.S. 322, 340 (2003). The “AEDPA thus imposes a ‘highly deferential standard for evaluating state-court rulings,’ and ‘demands that state-court decisions be given the benefit of the doubt.’” Renico v. Lett, 559 U.S.

766, 773 (2010) (quoting Lindh v. Murphy, 521 U.S. 320, 333, n. 7 (1997); Woodford v. Viscotti, 537 U.S. 19, 24 (2002) (per curiam)). “A state court’s determination that a claim lacks merit precludes federal habeas relief so long as ‘fairminded jurists could disagree’ on the correctness of the state court’s decision.” Harrington v. Richter, 562 U.S. 86, 101 (2011) (citing Yarborough v. Alvarado, 541 U.S. 652, 664 (2004)). The Supreme Court has emphasized “that even a strong case for relief does not mean the state court’s contrary conclusion was unreasonable.” Id. (citing Lockyer v. Andrade, 538 U.S. 63, 75 (2003)); see also Cullen v. Pinholster, 563 U.S. 170, 181 (2011) (describing the AEDPA standard as “a difficult to meet and highly deferential standard for evaluating state-court rulings, which demands that state-court decisions be given the benefit of the doubt”) (internal quotation marks and citations omitted).

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