Park v. Williams

CourtDistrict Court, D. Nevada
DecidedApril 8, 2021
Docket2:19-cv-01298
StatusUnknown

This text of Park v. Williams (Park v. Williams) 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
Park v. Williams, (D. Nev. 2021).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 KEON KYUN PARK, Case No.: 2:19-cv-01298-APG-BNW

4 Petitioner, ORDER

5 v.

6 CALVIN JOHNSON, et al.,

7 Respondents.

9 I. INTRODUCTION 10 Keon Kyun Park is incarcerated at Nevada’s High Desert State Prison. He filed this 11 petition for writ of habeas corpus under 28 U.S.C. § 2254. He is represented by appointed 12 counsel. Park challenges his convictions and sentences, imposed in Nevada’s Eighth Judicial 13 District Court upon guilty pleas, of conspiracy to commit murder, conspiracy to commit 14 kidnapping, first-degree kidnapping with use of a deadly weapon, first-degree murder with use of 15 a deadly weapon, and robbery with use of a deadly weapon. The respondents filed an answer, 16 and Park filed a reply. I will deny Park’s petition and deny a certificate of appealability. 17 II. BACKGROUND 18 Park was charged by indictment on January 19, 2011. Ex. 3, ECF No. 28-3. On May 13, 19 2014, he entered into a guilty plea agreement, under which he agreed to plead guilty, pursuant to 20 North Carolina v. Alford, 400 U.S. 25 (1970), to all five charges against him. Ex. 87, ECF No. 21 32-1 (plea agreement); see also Ex. 86, ECF No. 31-25 (amended indictment). In return the 22 State agreed to withdraw its notice of intent to seek the death penalty on the murder charge. See 23 id. at 3. Park entered his guilty plea on May 13, 2014, and on August 15, 2014 he was sentenced 1 to life in prison without possibility of parole for the murder, a consecutive term of 60 to 180 2 months in prison on the deadly weapon enhancement relative to the murder, and concurrent 3 prison sentences for the other crimes. Ex. 92, ECF No. 32-6 (transcript of sentencing). The 4 judgment of conviction was filed on August 18, 2014. Ex. 93, ECF No. 33-1.

5 Park appealed and the Supreme Court of Nevada affirmed the conviction on September 6 11, 2015. Ex. 106, ECF No. 33-14. 7 Park filed a pro se post-conviction petition for writ of habeas corpus in the state district 8 court on March 10, 2016. Ex. 109, ECF No. 33-17. Counsel was appointed and, with counsel, 9 Park twice supplemented his petition. Ex. 119, ECF No. 34-4; Ex. 132, ECF No. 35-1. The court 10 held an evidentiary hearing on July 16, 2018. Ex. 137, ECF No. 36-5 (transcript). On August 16, 11 2018, the court denied Park’s petition in a written order. Ex. 139, ECF No. 36-7. Park appealed, 12 and the Nevada Court of Appeals affirmed on June 11, 2019. Ex. 148, ECF No. 36-16. 13 This court received a pro se habeas petition from Park initiating this action on July 26, 14 2019. ECF No. 5. I appointed counsel for Park and, with counsel, Park filed an amended petition

15 on April 2, 2020. ECF No. 18. Park’s amended petition sets forth the following claims for relief, 16 all of which concern his sentencing: 17 Ground 1: The sentence of life without possibility of parole violates Park’s federal constitutional rights to due process of law and to be free from cruel and 18 unusual punishment.

19 Ground 2: Park’s federal constitutional rights were violated because he received ineffective assistance of trial counsel. 20 A. Trial counsel failed to object when the judge did not articulate 21 reasoning for Park’s sentence.

22 B. Trial counsel failed to object to the prosecutor’s assertion that an Alford plea meant Park lacked remorse. 23 1 C. Trial counsel failed to use Park’s co-defendant’s statements at sentencing. 2 Ground 3: Park’s federal constitutional rights were violated because he received 3 ineffective assistance of appellate counsel, because counsel failed on Park’s direct appeal to challenge the trial court’s failure to articulate reasoning for Park’s 4 sentence.

5 Ground 4: Park’s federal constitutional rights were violated as a result of the cumulative effect of the errors alleged in Grounds 1, 2 and 3. 6

7 ECF No. 18. The respondents filed an answer on July 16, 2020. ECF No. 25. Park filed a reply 8 on November 9, 2020. ECF No. 39. 9 III. DISCUSSION 10 A. Standard of Review 11 Under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a federal 12 court may not grant a petition for a writ of habeas corpus on any claim that was adjudicated on 13 its merits in state court unless the state court decision was contrary to, or involved an 14 unreasonable application of, clearly established federal law as determined by precedent of the 15 Supreme Court of the United States, or was based on an unreasonable determination of the facts 16 in light of the evidence presented in the state-court proceeding. 28 U.S.C. § 2254(d). A state- 17 court ruling is “contrary to” clearly established federal law if it either applies a rule that 18 contradicts governing Supreme Court law or reaches a result that differs from the result the 19 Supreme Court reached on “materially indistinguishable” facts. See Early v. Packer, 537 U.S. 3, 20 8 (2002) (per curiam). A state-court ruling is “an unreasonable application” of clearly 21 established federal law under section 2254(d) if it correctly identifies the governing legal rule but 22 unreasonably applies the rule to the facts of the case. See Williams v. Taylor, 529 U.S. 362, 407– 23 08 (2000). To obtain federal habeas relief for such an “unreasonable application,” however, a 1 petitioner must show that the state court’s application of Supreme Court precedent was 2 “objectively unreasonable.” Id. at 409–10; see also Wiggins v. Smith, 539 U.S. 510, 520–21 3 (2003). Or, in other words, habeas relief is warranted, under the “unreasonable application” 4 clause of section 2254(d), only if the state court’s ruling was “so lacking in justification that

5 there was an error well understood and comprehended in existing law beyond any possibility for 6 fairminded disagreement.” Harrington v. Richter, 562 U.S. 86, 103 (2011). 7 B. Ground 1 8 In Ground 1, Park claims that the sentence of life without possibility of parole violates his 9 federal constitutional rights to due process of law and to be free from cruel and unusual 10 punishment. ECF No. 18, pp. 5–11. Park asserted this claim on his direct appeal, and the 11 Supreme Court of Nevada ruled against him: 12 Appellant argues that the district court abused its discretion by sentencing him to life without parole, amounting to a cruel and unusual sentence. Appellant 13 contends that a lesser sentence was warranted for many reasons, which mostly stem from his age (19) and immaturity, Korean cultural norms, and a lack of 14 stability in his formative years.

15 We have consistently afforded the district court wide discretion in its sentencing decision, see, e.g., Houk v. State, 103 Nev. 659, 664, 747 P.2d 1376, 16 1379 (1987), and will refrain from interfering with the sentence imposed by the district court “[s]o long as the record does not demonstrate prejudice resulting 17 from consideration of information or accusations founded on facts supported only by impalpable or highly suspect evidence,” Silks v. State, 92 Nev. 91, 94, 545 18 P.2d 1159, 1161 (1976). Regardless of its severity, a sentence that is within the statutory limits is not “cruel and unusual punishment unless the statute fixing 19 punishment is unconstitutional or the sentence is so unreasonably disproportionate to the offense as to shock the conscience.” Blume v. State, 112 Nev.

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Park v. Williams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/park-v-williams-nvd-2021.