Plch v. Warden

2004 DNH 127
CourtDistrict Court, D. New Hampshire
DecidedAugust 31, 2004
DocketCV-03-548-SM
StatusPublished

This text of 2004 DNH 127 (Plch v. Warden) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Plch v. Warden, 2004 DNH 127 (D.N.H. 2004).

Opinion

Plch v . Warden CV-03-548-SM 08/31/04 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Vaclav Plch, Petitioner

v. Civil N o . 03-548-SM Opinion N o . 2004 DNH 127 Jane Coplan, Warden, New Hampshire State Prison, Respondent

O R D E R

In August of 1999, the dismembered body of a woman was found

in the Piscataquog River in Manchester, New Hampshire. The

victim was identified as Mary Stetson and an autopsy revealed

that she died as a result of multiple stab wounds. Petitioner,

Vaclav Plch, soon became a suspect and, after detectives located

him in Texas, he was charged with Stetson’s murder.

During the course of his criminal trial, Plch moved to

suppress incriminatory statements he had given to police,

asserting that they had been obtained in violation of his Miranda

rights. See Miranda v . Arizona, 384 U.S. 436 (1966).

Specifically, Plch claimed that the interrogating officers had:

(1) conducted the functional equivalent of interrogation after he had invoked his right to counsel; and (2) failed to adequately

and accurately inform him of the full panoply of Miranda rights,

including, in particular, the right to have counsel present

during any questioning. The trial court denied Plch’s motion and

he was convicted of Stetson’s murder. In affirming Plch’s

conviction on appeal, the New Hampshire Supreme Court

specifically addressed and rejected his Miranda claims. State v .

Plch, 149 N.H. 608 (2003). Plch is currently serving a sentence

of life in prison without the possibility of parole.

Plch now seeks federal habeas corpus relief, see 28 U.S.C. §

2254, advancing the two Miranda claims that he fully exhausted at

the state court level. And, suggesting that there are no

genuinely disputed material facts, Plch moves for summary

judgment. The State objects and has itself moved for summary

judgment.

Standard of Review

Since passage of the Anti-Terrorism and Effective Death

Penalty Act of 1996 (“AEDPA”), 28 U.S.C. § 2254(d), the power to

grant federal habeas relief to a state prisoner with respect to

2 claims adjudicated on the merits in state court has been

substantially limited. Under AEDPA, a federal court may not

disturb a state conviction unless the state court’s adjudication

“resulted in a decision that 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)(2).

Alternatively, habeas relief may be granted if the state court’s

resolution of the issues before it “resulted in a decision that

was contrary t o , or involved an unreasonable application o f ,

clearly established Federal law, as determined by the Supreme

Court of the United States.” 28 U.S.C. § 2254(d)(1). See also

Williams v . Taylor, 529 U.S. 3 6 2 , 399 (2000).

Here, Plch attacks the underlying state court decision

pursuant to section 2254(d)(1). S o , to prevail on his petition,

he must demonstrate that the state court’s rejection of his

Miranda claims was contrary t o , or involved an unreasonable

application o f , clearly established Federal law, as determined by

the Supreme Court.

3 The United States Supreme Court recently explained the

distinction between decisions that are “contrary to” clearly

established federal law, and those that involve an “unreasonable

application” of that law.

Under the “contrary to” clause, a federal habeas court may grant the writ if the state court arrives at a conclusion opposite to that reached by [the Supreme] Court on a question of law or if the state court decides a case differently than [the Supreme] Court has on a set of materially indistinguishable facts. Under the “unreasonable application” clause, a federal habeas court may grant the writ if the state court identifies the correct governing legal principle from [the Supreme] Court’s decisions but unreasonably applies that principle to the facts of the prisoner’s case.

Williams, 529 U.S. at 412-13. The Court also noted that an

“incorrect” application of federal law is not necessarily an

“unreasonable” one.

[T]he most important point is that an unreasonable application of federal law is different from an incorrect application of federal law . . . . Under § 2254(d)(1)’s ‘unreasonable application’ clause, then, a federal habeas court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly. Rather, that application must also be unreasonable.

Id. at 410-11 (emphasis in original).

4 Finally, it probably bears noting that a state court need

not rely upon, nor need it even cite, Supreme Court precedent in

order to avoid resolving a petitioner’s claims in a way that is

“contrary to” or involves an “unreasonable application of”

clearly established federal law. See Early v . Packer, 537 U.S.

3 , 8 (2002) (“Avoiding these pitfalls does not require citation

of our cases - indeed, it does not even require awareness of our

cases, so long as neither the reasoning nor the result of the

state-court decision contradicts them.”) (emphasis in original).

With those principles in mind, the court turns to Plch’s

petition.

Discussion

I. Factual Background.

Because Plch does not challenge the factual findings made by

the state trial court and adopted by the state supreme court, see

28 U.S.C. § 2254(d)(2), they will be presented as set out in

State v . Plch, supra.

Lieutenant Putney interviewed the defendant in a police station interview room. He advised the defendant of his rights by reading each right listed on the Austin Police Department’s Miranda form, and asking the defendant if he

5 understood that right. With regard to the right to counsel, the following conversation took place:

MP Okay. It says you have the right to have a lawyer present to advise you prior to you [sic] during an questioning. Do you understand that?

VP Mmm.

MP Okay. If you are unable to hire a lawyer - okay, if you can’t afford a lawyer - you have the right to have, a h , you have a right to have a lawyer appointed to you - to advise you prior to and during any questioning.

VP Yeah, what does that mean?

MP That means that if you can’t afford one, what happens is you can apply u h , in court, you fill out an affidavit - a financial affidavit saying that you can’t afford a lawyer and the court will appoint one for you.

MP You understand that?

VP Yeah.

The defendant signed the Miranda waiver form and the interview proceeded for approximately forty-five minutes. At that point, the defendant stated: “Now I want my lawyer.” The following colloquy then occurred:

MP You want a lawyer?

MP You can have a lawyer, but we know what happened that night Billy. And you’ll get a lawyer. This was going to be an opportunity, I guess for you to try to convince us of the person you really are. But, that’s not gonna happen.

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Rhode Island v. Innis
446 U.S. 291 (Supreme Court, 1980)
Edwards v. Arizona
451 U.S. 477 (Supreme Court, 1981)
Smith v. Illinois
469 U.S. 91 (Supreme Court, 1984)
Rose v. Arkansas State Police
479 U.S. 1 (Supreme Court, 1986)
Duckworth v. Eagan
492 U.S. 195 (Supreme Court, 1989)
Early v. Packer
537 U.S. 3 (Supreme Court, 2002)
United States v. Gamache
156 F.3d 1 (First Circuit, 1998)
United States v. Lloyd C. Payne
954 F.2d 199 (Fourth Circuit, 1992)
State v. Phinney
370 A.2d 1153 (Supreme Court of New Hampshire, 1977)
Opinion of the Justices
381 A.2d 1204 (Supreme Court of New Hampshire, 1978)
State v. Plch
826 A.2d 534 (Supreme Court of New Hampshire, 2003)

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2004 DNH 127, Counsel Stack Legal Research, https://law.counselstack.com/opinion/plch-v-warden-nhd-2004.