Pults v. McBee

CourtDistrict Court, E.D. Missouri
DecidedSeptember 8, 2023
Docket4:23-cv-00463
StatusUnknown

This text of Pults v. McBee (Pults v. McBee) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pults v. McBee, (E.D. Mo. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

LORI L. PULTS, ) ) Petitioner, ) ) v. ) ) No. 4:23 CV 463 RWS CHRIS MCBEE, ) ) Respondent. )

MEMORANDUM AND ORDER This case is before me on the petition of Lori L. Pults for writ of habeas corpus pursuant to 28 U.S.C. § 2254. Pults asserts eight grounds for relief in her petition. Because none of her grounds for relief have merit and/or are procedurally defaulted, I will deny Pults’s petition. BACKGROUND On April 21, 2017, a jury convicted Pults of first-degree murder and armed criminal action. On June 26, 2017, the trial court sentenced her to life imprisonment without the possibility of parole, plus ten years. Pults’s conviction and sentence were affirmed on appeal. On January 29, 2019, the Missouri Supreme Court denied Pults’s motion for transfer. On April 19, 2019, Pults filed a timely pro se motion for post-conviction relief pursuant to Missouri Supreme Court Rule 29.15.1 The motion court conducted an

evidentiary hearing on June 21, 2021, and denied the amended post-conviction motion on September 21, 2021. The Missouri Court of Appeals affirmed the denial of Rule 29.15 relief on

December 20, 2022. The mandate issued in the post-conviction appeal on March 7, 2023. Pults then filed a timely petition for writ of habeas corpus on April 6, 2023. The Missouri Court of Appeals described the factual and procedural background of this case as follows:

In the late evening of May 3, 2015, Pults stabbed her boyfriend, Victim, twice in the chest while he was asleep in his recliner chair, causing his death. Later, Pults went to a neighbor's home and called 911. When police arrived, Pults repeatedly told one of the responding officers, “I killed him, I killed him.”

Pults was transported to the Sheriff’s Office and escorted to an interrogation room. Pults made an unsolicited statement to Deputy Kevin Gugliano (“Deputy Gugliano”) that “I just reacted. I didn't mean to. I just reacted. I'll tell the detective that, too.” Deputy Gugliano told Pults a detective would be in shortly and then left Pults alone in the room. Shortly thereafter, Pults asked to use the restroom and said she was cold. Detective Erin Doherty (“Detective Doherty”) took Pults to the restroom. Without prompting, Pults stated, “I still can't believe this is happening . . . He beat me up a week ago . . . . He's been beating me up.” Detective Doherty took Pults back to the interrogation room, and told Pults she would be with her shortly.

1 Pults filed a timely pro se motion, but her counsel filed an untimely amended motion. However, the motion court concluded that Pults was abandoned by counsel and accepted the amended motion as timely pursuant to Sanders v. State, 807 S.W.2d 493 (Mo. Banc 1991). ECF No. 7-20, p. 5 n. 3. A few minutes later, Deputy Gugliano came back into the room to give Pults a blanket. Again without prompting, Pults voluntarily stated: “I just can't understand that these hands—I remember, I remember holding the knife. I remember taking it from him. And I remember holding it, and then I just did it.” Deputy Gugliano then left the room. While Pults sat alone, she yelled out in a loud voice:

PULTS: Hey, I need to make a phone call. I need to make a phone call, please. Hello. [Door opens] PULTS: Hey, I need to make a phone call, please. DEPUTY GUGLIANO: Okay. PULTS: I—they’re gonna take my money, and I need to get a hold of my lawyer. DEPUTY GUGLIANO: Okay. Hold on one sec, okay?

Deputy Gugliano closed the door. About twenty-five minutes later, Detective Doherty came back into the interrogation room and advised Pults of her Miranda rights. Pults indicated she understood her rights, then began discussing her involvement in Victim’s death and admitted she stabbed Victim. Pults neither requested an attorney nor made any reference to contacting an attorney during the interview. The entirety of the events that transpired in the interrogation room were audio and video recorded.

The State charged Pults with one count of first-degree murder, in violation of Section 565.020 RSMo (2000), and an associated count of armed criminal action, in violation of Section 571.015. Prior to trial, Pults filed a motion to suppress statements made during the custodial interrogation. Pults argued she unequivocally invoked her right to counsel when she told Deputy Gugliano that she needed to “get a hold of my attorney,” however, Pults was not given an opportunity to speak with counsel and was then interrogated by Detective Doherty. Pults asserted that continuing the interrogation after she clearly and unequivocally asked to contact her attorney was a violation of her constitutional rights.

The trial court heard arguments on Pults’s motion to suppress, and the video recording from the interrogation room was offered and received into evidence. The trial court subsequently denied Pults’s motion, concluding, in part: Ms. Pults made one single statement wherein she mentioned talking to her lawyer. The statement was made in the same sentence where she wanted to make a call because “they're going to take my money.[”] The Court finds the statement to be ambiguous in that it is not clear that the request to talk to her lawyer was related to the money issue or to the police interview. Ms. Pults never asked for an attorney after Miranda warnings were given. The Court finds that this statement regarding talking to her lawyer was not a clear and unambiguous statement that a reasonable officer in Deputy Gugliano’s or Detective Doherty’s position which would have caused either of them to believe Ms. Pults had invoked her right to counsel [sic].

Thereafter, Pults filed a second motion to suppress statements based on additional evidence. Pults contended that during discovery, she received a supplemental report prepared by Deputy Gugliano supporting her “position that her request to talk to her lawyer was sufficiently clear and was understood by Deputy Gugliano.”

The trial court held another hearing on Pults’s second motion to suppress where both Deputy Gugliano and Detective Doherty testified. Specifically, Deputy Gugliano testified Pults “asked if she could talk to somebody about getting some money and that she was cold and needed to use the bathroom, and then she said something along the lines of I think I need to talk to a lawyer.” Based on these statement, Deputy Gugliano testified he did not clearly understand why Pults was asking for an attorney as she did not specifically state her reason. The trial court subsequently denied Pults’s second motion to suppress, stating the additional evidence from the second hearing “does not change the court's prior ruling.”

A jury trial was held. The State did not seek to admit the video recording of the police interview into evidence, however, Detective Doherty testified regarding Pults’s statements during the interview as to how the stabbing occurred. Following trial, the jury convicted Pults of the charged crimes. Pults was sentenced to consecutive terms of life imprisonment without the possibility of parole for first-degree murder and ten years’ imprisonment for armed criminal action.

ECF No. 7-13, pp. 2–5 (cleaned up).

In her petition for writ of habeas corpus, Pults raises eight grounds for relief: (1) The trial court erred in denying petitioner’s motion to suppress her interview with law enforcement in violation of the right to counsel;

(2) Trial counsel was ineffective for not better explaining the battered spouse self-defense instruction as opposed to the general self-defense instruction;

(3) Trial counsel was ineffective for not investigating a diminished capacity defense;

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Pults v. McBee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pults-v-mcbee-moed-2023.