Ray v. Jones

580 F. Supp. 655
CourtDistrict Court, N.D. Georgia
DecidedFebruary 17, 1984
DocketCiv. A. No. C 83-715 A
StatusPublished

This text of 580 F. Supp. 655 (Ray v. Jones) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ray v. Jones, 580 F. Supp. 655 (N.D. Ga. 1984).

Opinion

ORDER

VINING, District Judge.

In this 28 U.S.C. § 2254 habeas corpus action the petitioner seeks relief from a sentence of life imprisonment imposed on him for a conviction of the offense of murder. This is the petitioner’s second federal habeas corpus petition. In this petition the petitioner asserts that two constitutional errors occurred at his state court trial. First, he alleges that the evidence adduced at trial was insufficient to support his conviction, and, second he claims that he received ineffective assistance of counsel. In his first federal habeas corpus petition, which was filed almost seven years ago, the petitioner asserted four grounds of constitutional error, including a claim that the evidence presented by the state was insufficient to support his conviction for the offense of murder. Prior to the filing of his first federal habeas corpus petition, the petitioner filed a state habeas corpus petition which alleged seven grounds of constitutional error, including a claim that he was rendered ineffective assistance of counsel. This case was initially submitted to a magistrate pursuant to 28 U.S.C. § 636(b)(1) and Local Rule 290.

A. THE SUFFICIENCY OF THE EVIDENCE CLAIM

In his report and recommendation to this court the magistrate concluded that the petitioner’s challenge to the sufficiency of the evidence was precluded because the petitioner litigated this claim, albeit unsuccessfully, in his previous federal habeas corpus case. Under the doctrine of Sanders v. United States, 373 U.S. 1, 83 S.Ct. 1068, 10 L.Ed.2d 148 (1963), and Rule 9(b) of the Rules Governing Section 2254 Cases in the United States District Courts, if a habeas corpus claim was litigated previously on the merits, the subsequent claim constitutes a successive claim, and the district court may dismiss the claim if the “ends of justice” would not be served by readdressing the merits of the petitioner’s renewed [657]*657habeas corpus claim. Bass v. Wainwright, 675 F.2d 1204, 1206 (11th Cir.1982). Factors to be considered in evaluating whether the ends of justice will be served include a determination of whether there was a full and fair hearing with respect to the first petition and whether there has been an intervening change in the law. Sanders, 373 U.S. at 17-18, 83 S.Ct. at 1077; Smith v. Kemp, 715 F.2d 1459, 1468 (11th Cir.), cert. denied, — U.S.-, 104 S.Ct. 55, 78 L.Ed.2d 74 (1983). The petitioner shoulders the burden of demonstrating that the ends of justice would be served by the court’s redetermination of issues decided adversely to him in his previous habeas corpus case. Smith, 715 F.2d at 1468; Bass, 675 F.2d at 1206.

In this case the petitioner has failed to offer any evidence or argument to sustain his burden of showing why the ends of justice mandate this court to reconsider his sufficiency of the evidence claim. However, upon its own examination this court has discovered an intervening change in the law which affects the petitioner’s sufficiency of the evidence claim.

In the petitioner’s previous federal habeas corpus case the district court adopted the report and recommendation of the magistrate to whom the first petition was initially assigned. See Ray v. Hopper, Civil Action No. 78-70A (N.D.Ga., Apr. 30, 1979) (adopting magistrate’s report and recommendation filed on March 29, 1979). In the previous report and recommendation the magistrate stated the general proposition that challenges to the sufficiency of the evidence ordinarily are not proper matters for a federal district court to entertain when reviewing a petition for habeas corpus. The magistrate concluded, and the district court agreed, that the standard of review in a federal habeas corpus case raising a sufficiency of evidence claim is whether there is any evidence in the record to sustain the conviction. Specifically, the magistrate held: “The habeas corpus petitioner must demonstrate a total lack of evidence supporting the conviction,” in order to prevail on a sufficiency of the evidence claim. Report and Recommendation at 2. The magistrate apparently relied upon Thompson v. Louisville, 362 U.S. 199, 80 S.Ct. 624, 4 L.Ed.2d 654 (1960), and the cases construing Thompson which held that a challenge to the sufficiency of the evidence would be unsuccessful if there was any evidence in the record to support a conviction. See Eleuterio v. Wainwright, 587 F.2d 194, 196-97 (5th Cir.), cert. denied, 443 U.S. 915, 99 S.Ct. 3106, 61 L.Ed.2d 879 (1979); Anderson v. Maggio, 555 F.2d 447, 452 (5th Cir.1977).

However, subsequent to the district court’s order adopting the magistrate’s report and recommendation, the Supreme Court abandoned the Thompson “any evidence” standard of review and articulated a new standard to be employed when a federal district court entertaining a section 2254 petition embarks on the task of determining whether a state court conviction is supported by sufficient evidence. In Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979), the Supreme Court held that when evaluating a challenge to the sufficiency of the evidence the critical inquiry is not whether there is any evidence to support the conviction but “whether the record evidence could reasonably support a finding of guilt beyond a reasonable doubt.” Id. at 318, 99 S.Ct. at 2788-89. The Court instructed that the federal habeas corpus court’s role is limited to a determination of “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Id. at 319, 99 S.Ct. at 2789 (emphasis in original). The Jackson standard is much higher than the Thompson standard, since a mere scintilla of evidence would satisfy the latter standard but probably would not satisfy the former standard. Jackson has been applied retroactively in this circuit. See Holloway v. McElroy, 632 F.2d 605, 637-39 (5th Cir.1980), cert. denied, 451 U.S. 1028, 101 S.Ct. 3019, 69 L.Ed.2d 398 (1981). In this case when considering the petitioner’s first habeas corpus petition both the magistrate and the district [658]*658court applied the Thompson standard. Since the Jackson case constitutes an intervening change in the law, this court determines that the ends of justice mandate the reconsideration of the merits of the petitioner’s sufficiency of the evidence claim.1

B. THE INEFFECTIVE ASSISTANCE OF COUNSEL CLAIM

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580 F. Supp. 655, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ray-v-jones-gand-1984.