Pectol v. Secretary, Department of Corrections

CourtDistrict Court, S.D. Florida
DecidedMay 3, 2023
Docket0:22-cv-61525
StatusUnknown

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

Bluebook
Pectol v. Secretary, Department of Corrections, (S.D. Fla. 2023).

Opinion

United States District Court for the Southern District of Florida

Donna Pectol, ) Petitioner ) ) v. ) Civil Action No. 22-61525-Scola ) Sec’y, Fla. Dep’t of Corr., Respondent.

Order on Petition for Writ of Habeas Corpus Before the Court is Petitioner Donna Pectol’s pro se petition for writ of habeas corpus under 28 U.S.C. § 2254. (ECF No. 1). The Petitioner challenges the constitutionality of her state convictions and sentences on charges of first- degree murder in the Seventeenth Judicial Circuit for Broward County. The Respondent filed a response (ECF No. 10), with an index to appendix (ECF No. 10-1) including attached exhibits 1–18 (ECF No. 10-2) and a notice of filing transcripts (ECF No. 11) with the attached trial transcript (ECF No. 11-1) and sentencing transcript (ECF No. 11-2). The Court has carefully reviewed the parties’ written submissions, the record, and applicable law. For the reasons explained below, the petition is dismissed in part and denied in part. 1. Background On June 25, 2015, the Petitioner was indicted on one count of first- degree murder with a deadly weapon. (See ECF No. 10-2 at 2–3). She proceeded to trial and the jury heard from multiple witnesses that the Petitioner and victim were neighbors who had been friends but were no longer friends around the time of the incident. (See ECF No. 11-1 at 781, 812). On the incident day, several neighbors responded to the victim’s screams. (See id. at 696). Through a clouded glass window, they could see the victim inside her home being stabbed by the Petitioner. (See id. at 692–94). The neighbors entered, the Petitioner retreated, and the victim died shortly thereafter in a pool of her own blood. (See id. at 696). The Petitioner was discovered hiding in a bedroom inside the victim’s home. (See id. at 819–20). The Petitioner appeared calm, alert, and uninjured. (See id. at 819–20). When asked what she had done, the Petitioner raised her hands and stated “what have I done? What have I done? She’s going to be just fine. She’s going to be fine.” (Id. at 820:11–12). Three bloody knifes were discovered in the home. (See id. at 929–33). On September 28, 2018, the jury found the Petitioner guilty as charged. (See ECF No. 10-2 at 5). She was adjudicated guilty and sentenced to a mandatory term of life in prison. (See id. at 7–8). The Petitioner appealed, and on January 30, 2020, the Fourth District Court of Appeal per curiam affirmed her conviction without a written opinion. See Pectol v. State, 289 So. 3d 903 (Fla. 4d DCA 2020). Back at the trial court, the Petitioner filed a Rule 3.850 motion for postconviction relief which was denied and affirmed on appeal. See Pectol v. State, 339 So. 3d 352 (Fla. 4d DCA 2022). The instant petition was docketed on August 2, 2022. 2. Legal Standard Deference Under § 2254 A court’s review of a state prisoner’s federal habeas corpus petition is governed by the Antiterrorism and Effective Death Penalty Act (“AEDPA”). See Abdul–Kabir v. Quarterman, 550 U.S. 233, 246 (2007). AEDPA “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). “The purpose of AEDPA is to ensure that federal habeas relief functions as a guard against extreme malfunctions in the state criminal justice systems, and not as a means of error correction.” Ledford v. Warden, Ga. Diagnostic & Classification Prison, 818 F.3d 600, 642 (11th Cir. 2016). This standard is “difficult to meet.” White v. Woodall, 572 U.S. 415, 419 (2014). According to AEDPA, a federal court may not grant a habeas petitioner relief on any claim adjudicated on the merits in state court unless the state court’s decision (1) “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) “was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” 28 U.S.C. § 2254(d); see also Rimmer v. Sec’y, Fla. Dep’t of Corr., 876 F.3d 1039, 1053 (11th Cir. 2017) (citing 28 U.S.C. § 2254(d)). A state court decision is “contrary to” established Supreme Court precedent when it (1) applies a rule that contradicts the governing law set forth by the Supreme Court; or (2) confronts a set of facts materially indistinguishable from a decision of the Supreme Court and nevertheless arrives at a result different from Supreme Court precedent. Williams v. Taylor, 529 U.S. 362, 405-06 (2000). An “unreasonable application” of clearly established federal law is different from an incorrect application of federal law. Id. at 410. Consequently, “[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). If the last state court to decide a prisoner’s federal claim provides an explanation for its merits-based decision in a reasoned opinion, “a federal habeas court simply reviews the specific reasons given by the state court and defers to those reasons if they are reasonable.” Wilson v. Sellers, 138 S. Ct. 1188, 1192 (2018). Even summary rejection of a claim, without explanation, qualifies as an adjudication on the merits, warranting deference. See Meders v. Warden, Ga. Diagnostic Prison, 911 F.3d 1335, 1351 (11th Cir. 2019). If the state court’s merits determination is unaccompanied by an explanation, federal courts should “‘look through’ the unexplained decision to the last related state-court decision that does provide a relevant rationale” and “presume that the unexplained decision adopted the same reasoning.” Wilson, 138 S. Ct. at 1192. Furthermore, a decision is still an adjudication on the merits when it “addresses some but not all of a defendant’s claims.” Johnson v. Williams, 568 U.S. 289, 298 (2013). Ineffective Assistance of Counsel The Sixth Amendment to the United States Constitution guarantees criminal defendants the right to assistance of counsel during criminal proceedings. See Strickland v. Washington, 466 U.S. 668, 684-85 (1984). When assessing counsel’s performance under Strickland, the Court employs a strong presumption that counsel “rendered adequate assistance and made all significant decisions in the exercise of reasonable professional judgment.” Id. at 690. “[T]he Sixth Amendment does not guarantee the right to perfect counsel; it promises only the right to effective assistance[.]” Burt v. Titlow, 571 U.S. 12, 20 (2013). “Where the highly deferential standards mandated by Strickland and AEDPA both apply, they combine to produce a doubly deferential form of review that asks only ‘whether there is any reasonable argument that counsel satisfied Strickland’s deferential standard.’” Gissendaner v. Seaboldt, 735 F.3d 1311, 1323 (11th Cir. 2013) (quoting Harrington v. Richter, 562 U.S. 86, 105 (2011)). To prevail on a claim of ineffective assistance of counsel, a petitioner must demonstrate both (1) that counsel’s performance was deficient; and (2) a reasonable probability that the deficient performance prejudiced the defense. See Strickland, 466 U.S. at 687-88; see also Harrington, 562 U.S. at 104.

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