Nelson v. Lamb

CourtDistrict Court, D. Arizona
DecidedMay 14, 2021
Docket2:20-cv-00492
StatusUnknown

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

Bluebook
Nelson v. Lamb, (D. Ariz. 2021).

Opinion

1 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Donald Kenneth Nelson, No. CV-20-00492-PHX-DLR (MTM)

10 Petitioner, ORDER

11 v.

12 Mark Lamb, et al.,

13 Respondents. 14 15 16 Before the Court is the Report and Recommendation (“R&R”) of Magistrate Judge 17 Michael T. Morrissey (Doc. 24) regarding Petitioner’s Petition for Writ of Habeas Corpus 18 filed pursuant to 28 U.S.C. § 2254 (Doc. 1). The R&R recommends that the Petition be 19 denied and dismissed with prejudice. The Magistrate Judge advised the parties that they 20 had fourteen days from the date of service to file specific written objections with the Court. 21 (Doc. 24 at 21-22.) Petitioner filed objections to the Magistrate’s R&R on March 17, 2021 22 (Doc. 25), and Respondents filed their response on March 24, 2021 (Doc. 26). The Court 23 has considered the objections and reviewed the R&R de novo. See Fed. R. Civ. P. 72(b); 24 28 U.S.C. § 636(b)(1). For the following reasons, the R&R is accepted. 25 Petitioner was convicted of one count of driving while impaired and one count of 26 extreme DUI in violation of Arizona law. The Petition raises three grounds for relief. In 27 Ground One, Petitioner claims he was denied due process because he was convicted by 28 blood evidence that was drawn from him on the night of his arrest and allegedly tampered 1 with by the state. In Ground Two, he claims the trial court’s restriction on cross- 2 examination denied him the right to confront witnesses. In Ground Three, he alleges that 3 the convictions for both extreme DUI and driving while impaired to the slightest degree 4 subjected him to double jeopardy. 5 The R&R correctly found Ground One meritless. It explained that Petitioner 6 failed to meet his burden of proving, by clear and convincing evidence, that the state 7 court’s factual determination—that he failed to prove that the blood sample was tampered 8 with—was incorrect. In his objection, Petitioner persists that he carried his burden of 9 showing that the blood was tampered with. (Doc. 25 at 2.) He claims the outer bag 10 containing the evidence was not sealed properly and the Department of Public Safety 11 (“DPS”) did not include the tracking number of the sample. In further support of his 12 argument, he presented two granular still photos from the blood-drawing officer’s 27- 13 minute body cam video and his own self-serving affidavit about the amount of alcohol he 14 consumed. The R&R correctly pointed out that the photos do not show or prove what 15 Petitioner argues. After reviewing the video, the Magistrate Judge correctly determined 16 that “Petitioner’s interpretation of the video footage is incorrect, and certainly does not 17 establish clear and convincing evidence that the blood samples were tampered with.” 18 (Doc. 24 at 13.) Petitioner’s photos do not clearly show three vials and the R&R 19 correctly found that the video shows that, just before the blood was drawn, there were 20 only two vials in the testing tray, not three. 21 Relatedly, Petitioner argues that the state’s late disclosure of the body-cam video, 22 after the motion to suppress was decided, made the denial of an evidentiary hearing 23 unreasonable. However, as the R&R explained, Petitioner’s interpretation of the video 24 and his arguments based on the video are not consistent with what the video shows. 25 Petitioner has not demonstrated that an evidentiary hearing would have resulted in the 26 suppression of any evidence. Likewise, Petitioner has not shown that an evidentiary 27 hearing would have developed any relevant evidence to support his Ground One claim. 28 1 Petitioner also disagrees with the R&R’s determination that “[a]t most, Petitioner 2 established that the seals on the vials were loose and that there was an opportunity for the 3 blood samples to have been tampered with, not that they actually were tempered with” 4 (Doc. 24 at 12), arguing that “[u]ndoubtedly, an expert could enhance the picture to the 5 pixel level and say to a reasonable certainty the three objects in the bag are the same type 6 of object by the color of the pixels.” (Doc. 25 at 4.) The point Petitioner misses is that 7 the burden of proof of his. Mere speculation about what an expert could find from the 8 evidence does not come close to meeting that burden. To the naked eye, and in the 9 context of the other portions of the video, the photos do not show what Petitioner claims 10 they show. 11 Overall, Petitioner disagrees with the R&R’s Ground One findings by making the 12 same arguments set forth in his Petition. However, the R&R correctly applied the 13 standard when it found that the Pinal County Superior Court’s denial of Ground One was 14 neither contrary to nor an unreasonable application of clearly-established federal law nor 15 that the state-court decision was based on an unreasonable factual determination. The 16 blood tampering theory was presented to the jury, who rejected Petitioner’s arguments. 17 Evidence supports the jury’s findings and Petitioner’s disagreement with the jury’s 18 verdict and the superior court’s rejection of his claim does not support federal habeas 19 relief. The R&R correctly concluded that Petitioner failed to carry his burden of proof. 20 See Davis v. Ayala, 576 U.S. 257, 276 (2015). 21 Next, the R&R correctly found Ground Two meritless. The claim is based on the 22 limits the trial court imposed on Petitioner’s cross-examination of two prosecution 23 witnesses. First, Petitioner was not allowed to cross-examine Officer Campano 24 (“Campano”), who performed the blood draw on Petitioner, about a 2008 incident in 25 which Campano received a reprimand for telling a police dispatcher to log him as 26 answering a call he did not answer. Second, Petitioner was not allowed to cross-examine 27 DPS Criminalist Patrick Harding (“Harding”) about a lawsuit brought by another DPS 28 Criminalist against DPS for retaliation after testifying in an alleged unsatisfactory manner 1 in another matter. The R&R correctly found that Petitioner had failed to demonstrate 2 both that trial court erred by placing the limits on cross-examination and that the error 3 was more than harmless. 4 The limits the trial court placed on the cross-examination of Campano did not 5 unreasonably apply the law as set forth in Delaware v. Van Arsdall, 475 U.S. 673, 680 6 (1986). The incident that Petitioner sought to explore in Campano’s cross-examination 7 occurred nearly nine years prior to trial and bore no factual resemblance to the issues in 8 Petitioner’s case. Petitioner argues that this evidence might have caused the jury to look 9 at him in a new light, that the credibility of Campano was so important that it warranted 10 the appointment of an expert to examine the video and stills, and that Campano might 11 have been impeached. (Doc. 25 at 8.) However, Petitioner’s speculation about what an 12 expert might find is a confession of his failure to carry his burden. The Trial court’s 13 ruling was neither contrary to nor an unreasonable application of clearly-established 14 federal law nor was the state-court decision based on an unreasonable factual 15 determination. 16 The R&R also correctly found that, even had the limits on cross-examination 17 violated Petitioner’s Confrontation Clause rights, the constitutional error was harmless 18 beyond a reasonable doubt. Van Arsdall, 475 U.S. at 681.

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Related

Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
Delaware v. Van Arsdall
475 U.S. 673 (Supreme Court, 1986)
Ricky Wahchumwah v. United States
710 F.3d 862 (Ninth Circuit, 2012)
Anderjeski v. City Court of City of Mesa
663 P.2d 233 (Arizona Supreme Court, 1983)
Davis v. Ayala
576 U.S. 257 (Supreme Court, 2015)

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Bluebook (online)
Nelson v. Lamb, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nelson-v-lamb-azd-2021.