PLATT v. ATTORNEY GENERAL OF PENNSYLVANIA

CourtDistrict Court, W.D. Pennsylvania
DecidedAugust 5, 2025
Docket2:20-cv-01799
StatusUnknown

This text of PLATT v. ATTORNEY GENERAL OF PENNSYLVANIA (PLATT v. ATTORNEY GENERAL OF PENNSYLVANIA) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PLATT v. ATTORNEY GENERAL OF PENNSYLVANIA, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

LEON PLATT, ) ) Petitioner, ) Civil Action No. 2:20-cv-1799 ) v. ) ) Magistrate Judge Patricia L. Dodge ATTORNEY GENERAL OF ) PENNSYLVANIA, et al., ) ) Respondents.

MEMORANDUM Pending before the Court1 is the Amended Petition for a Writ of Habeas Corpus (ECF No. 48) filed by Leon Platt (“Petitioner”) under 28 U.S.C. § 2254. Petitioner challenges the judgment of sentence imposed on him by the Court of Common Pleas of Lawrence County at criminal docket numbers CP-37-CR-0001417-2013, CP-37-CR-0001432-2013, and CP-37-CR-0001434-2013. For the reasons below, the Court will deny the petition and will deny a certificate of appealability. I. Introduction Petitioner raises four grounds for relief in his Amended Petition:2 (1) a violation of his due process rights stemming from an undisclosed deal between the prosecution and a trial witness; (2)

1 In accordance with the provisions of 28 U.S.C. § 636(c)(1), the parties voluntarily consented to have a United States Magistrate Judge conduct proceedings in this case, including entry of a final judgment. 2 Petitioner lists two additional grounds for relief in his Reply. (ECF No. 71 at 8-11.) A habeas petitioner cannot raise new claims in a reply (formerly known as a traverse) or in other filings made after the respondent has filed the answer. Therefore, the only claims properly before the Court are those Petitioner raised in the Amended Petition. See Rule 2(c) of the Rules Governing Section 2254 Cases in the United States District Courts (“The petition must: (1) specify all the grounds for relief available to the petitioner …. [.]”) (emphasis added); Local Rule 2254.B.2.b (“The petitioner is to state all grounds for relief …. (emphasis in original)); Paragraph 12 of standard form (“For this petition, state every ground on which you claim that you are being held in violation of the Constitution, laws, or treaties of the United States.”) (emphasis added). See also Footnote continued on next page… ineffective assistance of trial counsel for failure to: (a) obtain an expert witness concerning bullet trajectory; (b) “consult Taylor Foley public defender about deal”; (c) interview Foley after she recanted her testimony; and (d) file a post-sentence motion challenging the weight of the evidence; (3) denial of his right to confront witnesses against him; and (4) violation of the Grand Jury Clause

of the Fifth Amendment. II. Relevant Background Petitioner was convicted at a jury trial of murder of the third degree, recklessly endangering another person (two counts), persons not to possess or use firearms, firearms not to be carried without a license, discharge of a firearm into an occupied structure, and criminal mischief. The Superior Court of Pennsylvania summarized the underlying facts as follows: On November 11, 2013, [Petitioner] and Taylor Foley (“Foley”) went to the home of Michael Pounds, with whom Foley and [Petitioner] had an ongoing dispute. Foley drove the two to Mr. Pounds’ home in a white Chevrolet Cruz owned by Foley’s mother. [Petitioner] fired shots toward and into the side of the house. The bullets did not pass through to the interior of the home, but at least some bullets stuck in the house. Police found four .45 caliber shell casings around Pounds’ home.

On the evening of November 15, 2013, [Petitioner], Foley, Foley’s infant child, LaXavier Crumb (“Crumb”), Heather Hall (“Hall”), and Shane Mihalko (“Mihalko”) were at Hall and Crumb’s apartment at 411 Loop Street. That night, [Petitioner], Foley, Crumb, and Richard Hogue (the “Victim”) left 411 Loop Street and drove to the West End Café.

The group drove to a road behind the West End Café, and [Petitioner] and Foley exited the vehicle. Foley shot her 9 mm pistol and [Petitioner] shot his .45 caliber Kimber pistol near the West End Café, hitting the car of Linda Boots and going through the window of Tim and Allison Phillippi’s residence at 1217 Lawrence Ave.[fn 4] Crumb and the Victim stayed in the car.[fn 5]

Following the shooting, [Petitioner], Crumb, Foley, and the Victim returned to 411 Loop Street. Foley and the Victim left to get cigarettes and, while they were out, checked to see the damage [Petitioner] and Foley had caused by the shooting at the West End Café.

Cacoperdo v. Demosthenes, 37 F.3d 504, 507 (9th Cir. 1994) (“A Traverse is not the proper pleading to raise additional grounds for relief.”) Upon their return to 411 Loop Street, an argument between the Victim and [Petitioner] about the scope of the damage caused by [Petitioner] and Foley ensued.

[Petitioner] was on one side of the room in a rocking chair, Foley and her baby were on a loveseat adjacent to the chair. The Victim was in the middle of a couch across the room from [Petitioner] with Crumb to his left and Mihalko to his right, and a coffee table in the middle of the seating arrangement. As the argument got more intense, Mihalko, sensing trouble, left the house. The argument continued and both the Victim and [Petitioner] stood up across the living room from each other. Foley then covered her baby in a protective position, [Petitioner] raised his .45 caliber Kimber pistol and shot the Victim once. The Victim later died.

After [Petitioner] shot the Victim, [Petitioner], Crumb, and Hall all left 411 Loop Street. Foley stayed at the house with the Victim and called 911. When the police arrived, they spoke with Foley who eventually told them that [Petitioner] was the shooter and gave them a description of him. [Petitioner], who was allegedly at Foley’s parents’ residence, called Foley.[fn 6]

After being called to El[l]wood City to investigate the shooting, Sgt. Matthew Smock, of nearby Koppel Borough, observed [Petitioner] heading away from El[l]wood City. Upon the arrest, [Petitioner] identified himself as “Mike.” The Koppel Borough officers exchanged custody of [Petitioner] with the Pennsylvania State Police, who transported him to the El[l]wood City Police Department.

* * *

[footnote 4] Both Tim and Allison Phillippi were present in the living room when the bullets went through the living room window.

[footnote 5] After investigating the scene, police found five empty .45 caliber casings and two empty 9 mm casings near Linda Boots’ Jeep, and a bullet hole in its passenger side door. Police also found two bullet holes in the window of the Phillippi residence and one bullet fragment, which police determined to have come from Lawrence Avenue.

[footnote 6] Police conducted a protective sweep of the Foley residence, but did not find [Petitioner].

(ECF No. 23-21 at 2-4.) On August 3, 2016, Petitioner was sentenced to an aggregate term of 22 to 52 years’ imprisonment. The Superior Court of Pennsylvania affirmed his judgment of sentence on April 13, 2017. Commonwealth v. Platt, 169 A.3d 1169 (Pa. Super. 2017) (unpublished memorandum); (ECF No. 23-21.) Petitioner filed a petition for allowance of appeal in the Supreme Court of Pennsylvania which was denied on December 19, 2017. Commonwealth v. Platt, 176 A.3d 847 (Pa. 2017).

Petitioner did not file a petition for a writ of certiorari with the Supreme Court of the United States. On April 9, 2018, through his trial counsel, Petitioner filed a petition pursuant to Pennsylvania’s Post Conviction Relief Act (“PCRA”), 42 Pa.C.S. §§ 9541-46. (ECF No. 60-46). Subsequently, counsel amended the petition. (ECF No.

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PLATT v. ATTORNEY GENERAL OF PENNSYLVANIA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/platt-v-attorney-general-of-pennsylvania-pawd-2025.