Ralph D. Tucker v. Paul Schreiber

District Court, E.D. Michigan·Decided March 26, 2026·No. 2:25-cv-12163·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

RALPH D. TUCKER,

Petitioner, Case No. 2:25-cv-12163 v. Honorable Susan K. DeClercq PAUL SCHREIBER, United States District Judge

Respondent. _____________________________/ OPINION AND ORDER DENYING PETITIONER’S HABEAS PETITION (ECF No. 1), DENYING A CERTIFICATE OF APPEALABILITY, AND DENYING LEAVE TO PROCEED IN FORMA PAUPERIS ON APPEAL

Michigan prisoner, Petitioner Ralph Tucker, has filed a pro se petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254, asserting that he is being held in violation of his constitutional rights because his defense counsel was ineffective for failing to investigate and for failing to explain the effect of the sentencing guidelines on his minimum sentence before advising him to plead nolo contendere. For the reasons provided below, the Court will deny his petition, as well as a certificate of appealability and leave to proceed in forma pauperis on appeal. I. BACKGROUND Tucker’s convictions arise from multiple sexual assaults that he committed in Wayne County, Michigan from 1999 to 2003. On August 19, 2019, Tucker pleaded nolo contendere to six counts of first-degree criminal sexual conduct in violation of MICH. COMP. LAWS § 750.520B, pursuant to a plea bargain with a Cobbs sentencing evaluation. ECF No. 11-24. At the plea hearing, Tucker stated that he understood the charges, the plea agreement, and the life imprisonment maximum sentence he

faced. Id. at PageID.602–04. He confirmed that he was not under the influence of any substances and that he understood the rights that he would be giving up by pleading nolo contendere. Id. at PageID.604–06. The Parties acknowledged that no

other promises or threats had been made to Tucker to induce his plea and Tucker indicated that he was knowingly and voluntarily pleading nolo contendere. Id. at PageID.605–06. The prosecution offered a factual basis for the plea, and the Parties stipulated to the investigator’s report and the preliminary examination in support of

the factual basis. Id. at PageID.606–17. On September 17, 2019, the trial court conducted a hearing and sentenced Tucker to the concurrent terms of imprisonment set forth in accordance with his plea

agreement and Cobbs evaluation. ECF No. 11-25. Specifically, Tucker was sentenced to concurrent terms of 16 years and 6 months to 35 years in prison on two convictions and concurrent terms of 15 years to 35 years in prison on the other four convictions. Id. at PageID.642–43. Because Tucker had previously been convicted

of two other first-degree criminal sexual conduct convictions—which were imposed following a bench trial in the Wayne County Circuit Court—he was sentenced to concurrent terms of 16 years to 35 years in prison on those convictions at the same

- 2 - time. Id. at PageID.644–45. Thus, Tucker’s sentences in all cases are concurrent with each other. Following sentencing, Tucker went through several appellate attorneys and

eventually filed, through counsel, a motion to withdraw his plea with the state trial court, asserting that trial counsel was ineffective during the plea process.1 See ECF No. 11-26 at PageID.655. But on February 28, 2023, the trial court conducted a

hearing and denied the motion. See id. at PageID.656–64. Tucker then filed an application for leave to appeal with the Michigan Court of Appeals, raising the same claim presented on habeas review, which was denied “for lack of merit in the grounds presented.” ECF No. 11-29 at PageID.880; see also

People of Mich. v. Tucker, No. 365463 (Mich. Ct. App. May 17, 2023). Tucker also filed an application for leave to appeal with the Michigan Supreme Court, which was denied in a standard order. ECF No. 11-30 at PageID.1018; see also People of Mich.

v. Tucker, 996 N.W.2d 461 (Mich. Oct. 31, 2023). Tucker thereafter filed an initial federal habeas petition on September 23, 2024, raising the same claim presented in the instant petition. See Tucker v.

1 He also filed an appeal in the Michigan Court of Appeals arguing that his trial was unfair through insufficient evidence, erroneously admitted other-acts evidence, and a wrongful denial of his motion to suppress his statements to police. See ECF No. 11-27. On February 18, 2021, the Michigan Court of Appeals affirmed his convictions. See id.; see also People of Mich. v. Tucker, No. 351334 (Mich. Ct. App. Feb. 18, 2021). - 3 - Schreiber, No. 2:24-cv-12488, 2025 WL 629976 (E.D. Mich. Feb. 26, 2025), ECF No. 1. He also filed a motion to hold the petition in abeyance and stay the

proceedings so that he could exhaust additional claims of perjury at the preliminary examination and ineffective assistance of appellate counsel. See id., ECF No. 8. On February 26, 2025, this Court denied that motion, finding that he had sufficient time to exhaust additional claims in the state court and return to federal court with an

amended habeas petition. See id., ECF No. 9. Tucker then moved to voluntarily dismiss his case. See id., ECF No. 10. On March 19, 2025, the Court granted that request and dismissed the case without prejudice. See id., ECF Nos. 11; 12.

But rather than returning to the state courts, Tucker refiled the same habeas petition in this Court on July 16, 2025. ECF No. 1. He raises the following claims: [He] was denied his right to the effective assistance of counsel during the plea-bargaining process, when trial counsel failed to investigate potential witnesses and evidence and failed to explain the effect of the sentencing guidelines on [his] potential minimum sentence before advising [him] to plead nolo contendere. Therefore, the trial court and Michigan’s appellate courts abused [their] discretion and denied [him] due process of law in failing to allow [his] motion to withdraw his nolo contendere pleas.

Id. at PageID.2–3. Respondent Paul Schreiber filed an answer to the petition, contending that the petition should be dismissed as untimely under the one-year statute of limitations applicable to federal habeas actions and—or alternatively—the petition should be denied for lack of merit. ECF No. 10. Tucker then replied, asking - 4 - the Court to excuse his delay because he has “been dealing with a[n unspecified] medical issue for the last (2) years,” which resulted in a change of custody level and

law library access. ECF No. 12 at PageID.1035. II. LEGAL STANDARD Federal law imposes the following standard of review for habeas cases: 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 claim that was adjudicated on the merits in State court proceedings unless the adjudication of the claim—

(1) resulted in a decision that 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) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceedings.

28 U.S.C. § 2254(d). Under the first prong of § 2254(d)(1), a state court’s decision is “contrary to” clearly established federal law if the decision “‘applies a rule that contradicts the governing law set forth in [United States Supreme Court cases]’ or if it ‘confronts a set of facts that are materially indistinguishable from a decision of [the United States Supreme] Court and nevertheless arrives at a result different from [that] precedent.’” Mitchell v. Esparza, 540 U.S. 12

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