Nathan R. Hall v. Darren Galloway

CourtDistrict Court, S.D. Illinois
DecidedDecember 17, 2025
Docket3:22-cv-01398
StatusUnknown

This text of Nathan R. Hall v. Darren Galloway (Nathan R. Hall v. Darren Galloway) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nathan R. Hall v. Darren Galloway, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

NATHAN R. HALL,

Petitioner,

v. Case No. 3:22-CV-01398-NJR

DARREN GALLOWAY,

Respondent.

MEMORANDUM AND ORDER

ROSENSTENGEL, Chief Judge: Petitioner Nathan R. Hall, an inmate of the Illinois Department of Corrections who is currently incarcerated in this district at Shawnee Correctional Center, brings this habeas corpus action pursuant to 28 U.S.C. § 2254 to challenge the constitutionality of his state conviction. (Doc. 1). After conducting a preliminary review of the petition, the Court directed the Respondent Darren Galloway to file a response. Respondent argues that Hall has not properly preserved his claims for habeas review. For the reasons set forth below, the Court agrees that all of Hall’s claims are procedurally defaulted. The petition, therefore, is denied. BACKGROUND The Illinois Court of Appeals’ opinion denying Hall’s direct appeal comprehensively recounts the facts of his case. See People v. Hall, No. 5-19-0199, 2021 WL 2379824 (Ill. Ct. App. June 8, 2021). In 2018, Hall was charged in Jefferson County Circuit Court with one count of disseminating child pornography, 720 Ill. Comp. Stat. 5/11- 20/1(a)(2). Hall elected to proceed to trial.

A summary of the evidence presented at Hall’s trial is necessary to understand his claims. The State’s case consisted of two witnesses: Detective Bobby Wallace, a specialist in internet crimes against children, and Siobhan McCarthy, a computer evidence recovery technician from the Illinois Attorney General’s Office. Wallace explained that as part of his investigatory efforts he uses a software program to automatically track downloads comprising suspected child pornography. In June 2018, Wallace’s computer software

flagged a file associated with an IP address assigned to Hall. Wallace thereafter obtained a search warrant for Hall’s residence, and officers ultimately seized a computer and five hard drives. This evidence included the video containing suspected child pornography. After Wallace testified about the search, the State moved to admit the full 21-minute video into evidence. Without objection, the State played the video in its entirety for the jury.

Wallace then described how Hall was taken to the sheriff’s office for questioning. According to Wallace, Hall confirmed during his interview with police that he was aware the computer program from which he had accessed the video was a file-sharing program and confirmed that he viewed child pornography and would masturbate to it. The video of Hall’s interview, which was clipped to exclude his questions to officers about bail, was

published to the jury without objection. On cross examination, Wallace conceded that the age of the child depicted in the video was unknown but stated that in his training and experience, the individual was under the age of 13 and definitely was under age 18. Wallace also averred that the download was not a one-time incident based on Hall’s admission during the police interview that he had downloaded such content previously and other attempted downloads intercepted by Wallace.

Next up for the State, McCarthy, the evidence recovery technician, testified that she had reviewed the contents of one of the hard drives recovered during the search of Hall’s residence, as well as a portion of a second. She confirmed that the drives did not contain any child pornography but did contain certain adult pornography, some of which was Hentai, a Japanese anime style of pornographic imagery. The State moved to admit five of the images and, without objection from defense counsel, the images were

published to the jury. McCarthy confirmed that the images were not illegal. The State rested following McCarthy’s testimony. Hall elected to testify in his own defense. Put simply, his testimony was devastating to his case. He admitted, among other things, to being aware during his police interview that he was being investigated for child pornography, to downloading

child porn using a shared network program, and confirmed he had downloaded the video shown to the jury. He also acknowledged that he knew possession of child pornography was illegal. He explained that he was curious about the content and wanted to better understand why people were repulsed by it. On cross-examination, Hall stated that he did not want people to consider him repulsive and agreed that the video was

shareable, although he did not intend to share it. He did not present any other witnesses in his defense. During closing arguments, the State concluded by stating: So the defendant has confessed to you each and every element that I have to prove. He confessed it to you yesterday. Why? Why come in here and take the stand just to confess it all? Because he doesn’t want you to find him repulsive. That’s what he told you. He somehow in his mind thinks child pornography is okay, and I don't want you guys to think that I masturbate to it because that would be repulsive. I don’t have to prove that he masturbated to it. That is not an element. But you guys are still going to find that repulsive. The common person is going to find that repulsive no matter what you are doing with it.

And if after 16 years of studying human behavior you can’t figure out that that’s repulsive, then there’s nothing that is going to change that. But he thought if he got on the stand and explained that to you, you too would not find him repulsive and find him not guilty. But yet, he sat and confessed to every element that I have to prove. That’s why I would ask that you to return a verdict of guilty. Hall, 2021 WL 2379824, at *4-5. Defense counsel, in rebuttal, acknowledged many on the jury were “repulsed” by the film, but reminded them of the State’s burden to prove guilt beyond a reasonable doubt. He argued the State had not proven the individual depicted in the video was under the age of 13. The jury found Hall guilty. Before sentencing, his counsel moved to withdraw from the case because Hall wished to file a claim for ineffective assistance of counsel. New counsel was appointed, and the Court sentenced Hall to 20 years’ imprisonment. The trial court denied Hall’s motion for reconsideration. In his appeal of his conviction and sentence, Hall argued: 1. His trial counsel was ineffective for failing to object to: a. The full 21-minute video being played for the jury; b. The State’s use of the word “repulsive”; c. The State’s introduction of adult pornography and Hentai images; d. Questioning by the State in his cross-examination regarding the video that was unduly prejudicial.

2. The prosecutor committed misconduct by using the word “repulsive” to describe him and asking him to agree on cross-examination that the video met the elements of child pornography when he had already admitted as much.

3. The trial court abused its discretion when it denied Hall’s request for a lesser-included offense instruction for possession of child pornography rather than dissemination.

In his reply brief, Hall added that the prosecutor committed misconduct by introducing the Hentai images and playing the full video for the jury. The Illinois Court of Appeals affirmed Hall’s conviction. With regard to his claim that defense counsel was ineffective for failing to object to the State’s questioning on cross-examination, the court concluded that it was not unreasonable for trial counsel to refrain from objecting to the State’s questions, which were relevant to the matters raised on direct examination. Id. at *7. Similarly, the court held defense counsel was not ineffective for failing to object to the State’s use of the word “repulsive” considering the context in which the word was used. Id.

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