Phillip Charles Moore v. Jerry Howell

CourtDistrict Court, D. Nevada
DecidedNovember 16, 2025
Docket2:21-cv-01639
StatusUnknown

This text of Phillip Charles Moore v. Jerry Howell (Phillip Charles Moore v. Jerry Howell) 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
Phillip Charles Moore v. Jerry Howell, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Phillip Charles Moore, Case No.: 2:21-cv-01639-APG-MDC

4 Petitioner Order Denying Amended Petition and Certificate of Appealability 5 v. [ECF No. 34] 6 Jerry Howell1,

7 Respondents

8 Phillip Charles Moore has filed a counseled First Amended Petition for Writ of Habeas 9 Corpus under 28 U.S.C. § 2254. ECF No. 34. I deny the First Amended Petition and a 10 Certificate of Appealability. 11 I. Background 12 Moore was charged in state court with two counts of burglary while in possession of a 13 firearm, four counts of robbery with use of a deadly weapon, one count of conspiracy to commit 14 robbery, two counts of attempted robbery with use of a deadly weapon, one count of burglary, 15 and one count of attempted robbery. ECF No. 14-4 at 9. Moore pleaded guilty to one count of 16 burglary while in possession of a firearm and one count of robbery with use of a deadly weapon. 17 ECF No. 15-7. Under the guilty plea agreement, the State agreed not to seek habitual criminal 18 treatment, but both parties retained the right to argue for any sentence. ECF No. 14-8. 19 Moore informed the state district court that he wanted to withdraw his guilty plea. ECF 20 No. 14-10. The court appointed Adam Gill to represent Moore, and he filed a motion to 21

22 1 The state corrections department’s inmate locator page indicates that Moore is incarcerated at the Southern Desert Correctional Center. Ronald Oliver is the current warden for that facility. 23 At the end of this order, I direct the Clerk of the Court to substitute Ronald Oliver as respondent in place of Jerry Howell under Rule 25(d) of the Federal Rules of Civil Procedure. 1 withdraw guilty plea. ECF No. 14-11. The court denied Moore’s motion to withdraw his guilty 2 plea and sentenced Moore to an aggregate term of 12 to 35 years. ECF Nos. 15-2, 15-7. 3 The state district court denied Moore’s state habeas petition. ECF No. 17-1. The Nevada 4 Court of Appeals affirmed the denial of relief. ECF No. 18-5. Moore filed his pro se federal

5 petition. ECF No. 6. Following appointment of counsel, Moore filed his First Amended Petition 6 alleging four claims for relief. ECF No. 34. I denied the respondents’ motion to dismiss Grounds 7 1-4, deferring consideration on whether Moore can demonstrate cause and prejudice under 8 Martinez v. Ryan, 566 U.S. 1 (2012), to overcome the procedural default for Grounds 1, 2, and 9 42. ECF No. 56. However, I granted the respondents’ motion to exclude certain exhibits. Id. 10 II. Governing Standard of Review 11 a. Review under the Antiterrorism and Effective Death Penalty Act 12 The Antiterrorism and Effective Death Penalty Act sets forth the standard of review 13 generally applicable in habeas corpus cases: 14 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 15 claim that was adjudicated on the merits in State court proceedings unless the adjudication of the claim – 16 (1) resulted in a decision that was contrary to, or involved an unreasonable 17 application of, clearly established Federal law, as determined by the Supreme Court of the United States; or 18 (2) resulted in a decision that was based on an unreasonable determination of the 19 facts in light of the evidence presented in the State court proceeding.

20 28 U.S.C. § 2254(d). A state court decision is contrary to clearly established Supreme Court 21 precedent within the meaning of 28 U.S.C. § 2254(d) “if the state court applies a rule that 22

2 I found that Ground 4 was partially unexhausted to the extent Moore incorporates educational 23 records and an expert’s evaluation. ECF No. 56 at 11. Moore filed untimely affidavits before the state courts that the state courts declined to consider. Id. 1 contradicts the governing law set forth in [Supreme Court] cases” or “if the state court confronts 2 a set of facts that are materially indistinguishable from a decision of [the Supreme] Court.” 3 Lockyer v. Andrade, 538 U.S. 63, 73 (2003) (first quoting Williams v. Taylor, 529 U.S. 362, 405- 4 06 (2000), and then citing Bell v. Cone, 535 U.S. 685, 694 (2002)). A state court decision is an

5 unreasonable application of clearly established Supreme Court precedent within the meaning of 6 28 U.S.C. § 2254(d) “if the state court identifies the correct governing legal principle from [the 7 Supreme] Court’s decisions but unreasonably applies that principle to the facts of the prisoner’s 8 case.” Id. at 75. 9 “A state court’s determination that a claim lacks merit precludes federal habeas relief so 10 long as ‘fairminded jurists could disagree’ on the correctness of the state court’s decision.” 11 Harrington v. Richter, 562 U.S. 86, 101 (2011) (citing Yarborough v. Alvarado, 541 U.S. 652, 12 664 (2004)). 13 b. Standard for Evaluating an Ineffective Assistance of Counsel Claim 14 In Strickland, the Supreme Court propounded a two-prong test for analysis of ineffective

15 assistance of counsel (IAC) claims requiring the petitioner to demonstrate that: (1) the counsel’s 16 “representation fell below an objective standard of reasonableness[;]” and (2) the counsel’s 17 deficient performance prejudices the petitioner such that “there is a reasonable probability that, 18 but for counsel’s unprofessional errors, the result of the proceeding would have been different.” 19 Strickland v. Washington, 466 U.S. 668, 688, 694 (1984). Courts considering an ineffective 20 assistance of counsel claim must apply a “strong presumption that counsel’s conduct falls within 21 the wide range of reasonable professional assistance.” Id. at 689. It is the petitioner’s burden to 22 show “counsel made errors so serious that counsel was not functioning as the ‘counsel’ 23 guaranteed . . . by the Sixth Amendment.” Id. at 687. Additionally, to establish prejudice under 1 Strickland, it is not enough for the petitioner to “show that the errors had some conceivable 2 effect on the outcome of the proceeding.” Id. at 693. Rather, errors must be “so serious as to 3 deprive [the petitioner] of a fair trial, a trial whose result is reliable.” Id. at 687. 4 Where a state court previously adjudicated the ineffective assistance of counsel claim

5 under Strickland, establishing the court’s decision was unreasonable is especially difficult. See 6 Richter, 562 U.S. at 104-05. In Richter, the Supreme Court clarified that Strickland and 7 § 2254(d) are each highly deferential, and when the two apply in tandem, review is doubly so. 8 See id. at 105; see also Cheney v. Washington, 614 F.3d 987, 995 (9th Cir. 2010) (internal 9 quotation marks omitted). The Court further clarified, “[w]hen § 2254(d) applies, the question is 10 not whether counsel’s actions were reasonable. The question is whether there is any reasonable 11 argument that counsel satisfied Strickland’s deferential standard.” Richter, 562 U.S. at 105. 12 c.

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