REID v. THE PHILA D.A.'S OFFICE

CourtDistrict Court, E.D. Pennsylvania
DecidedMay 7, 2025
Docket2:18-cv-01645
StatusUnknown

This text of REID v. THE PHILA D.A.'S OFFICE (REID v. THE PHILA D.A.'S OFFICE) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
REID v. THE PHILA D.A.'S OFFICE, (E.D. Pa. 2025).

Opinion

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

GIOVANNI REID,

Petitioner, CIVIL ACTION v. NO. 18-1645

THE PHILADELPHIA D.A.’s OFFICE, et al.,

Respondents.

Slomsky, J. May 7, 2025

I. INTRODUCTION................................................................................................................. 3 II. BACKGROUND ................................................................................................................... 4 A. Procedural History ......................................................................................................... 4 B. Section 2254 Petitions .................................................................................................... 5 III. STANDARDS OF REVIEW ................................................................................................ 6 A. Magistrate Judge’s Report and Recommendation .......................................................... 6 B. Merits Review ................................................................................................................ 7 C. Exhaustion and Procedural Default ................................................................................ 9 IV. ANALYSIS ........................................................................................................................... 10 A. Petitioner’s Miller/Montgomery Claim ............................................................................... 10 1. Applicable Law ............................................................................................................ 10 2. Petitioner’s is Not Entitled to an Individualized Sentencing Hearing Under Miller v. Alabama or Montgomery v. Louisiana ................................. 12

3. Petitioner’s Maximum Sentence of Life Imprisonment, Which Upon His Release Resulted in a Sentence of Life on Parole, Does Not Violate Miller v. Alabama or Montgomery v. Louisiana ............................. 14

4. A Sentence For Second-Degree Murder Can Be Imposed on a Juvenile ..................... 16

B. Petitioner’s Actual Innocence Claim ................................................................................... 17 1. Petitioner’s Claim is Non-Cognizable on Federal Habeas Review ............................. 17

2. Petitioner’s Claim is Also Meritless ........................................................................... 18

i. Wayne Richman’s Statements ............................................................................... 19 ii. Tyrone Mackey’s Statements ............................................................................... 20 iii. Crime Scene Photographs ................................................................................... 21 C. Petitioner’s Adopted Admission Claim ............................................................................... 21 1. Petitioner’s Claim is Non-Cognizable on Federal Habeas Review ............................. 22

2. Second-Degree Murder ................................................................................................ 23

3. Respondents Did Not Adopt an Exonerating Statement .............................................. 25

V. CONCLUSION .................................................................................................................... 26 I. INTRODUCTION In 1991, Petitioner Giovanni Reid (“Petitioner”) was convicted of second-degree murder and related offenses after he and two co-conspirators robbed Robert Janke, who was shot and killed by one of the co-conspirators. Petitioner was 16 years old at the time of the murder and was sentenced to a mandatory sentence of life without parole.

After the United States Supreme Court decision in Miller v. Alabama, 567 U.S. 460 (2012), which held that mandatory sentences of life imprisonment without parole for persons under 18 years of age violated the Eighth Amendment to the United States Constitution, the Superior Court of Pennsylvania vacated Petitioner’s sentence of life imprisonment and he was resentenced to an agreed upon term of 25 years imprisonment to life imprisonment. Petitioner was immediately eligible for parole, was released from custody and was placed on parole for the remainder of his life. Before the Court is a pro se petition for Writ of Habeas Corpus, pursuant to 28 U.S.C. § 2254, filed by Petitioner against the Philadelphia District Attorney’s Office and the Attorney General of the State of Pennsylvania (collectively, “Respondents”). He argues that his new

maximum life imprisonment sentence and his placement on parole for life violate Miller v. Alabama. He further maintains that there is newly discovered evidence that proves he is actually innocent of second-degree murder. Lastly, he contends that Respondents adopted statements during his Post Conviction Relief Act (“PCRA”) hearing in state court that prove he is not guilty of second-degree murder. The Court referred the Petition to United States Magistrate Judge Lynne A. Sitarski for a Report and Recommendation. (Doc. No. 22.) On October 9, 2024, Judge Sitarski issued a Report and Recommendation, recommending that the Petition be denied. (Doc. No. 36.) Defendant filed objections to the Report and Recommendation which are now before the Court for consideration. (Doc. No. 39.) For reasons discussed below, however, the Court will adopt Judge Sitarski’s Report and Recommendation (Doc. No. 36) and deny the Petition for Writ of Habeas Corpus. (Doc. Nos. 2, 20). II. BACKGROUND A. Procedural History Respondents and Judge Sitarski have accurately summarized Petitioner’s state court case

as follows: In 1991, when he was 16 years old, Reid and two others [Dwayne and Carlton Bennett] robbed Robert Janke in Philadelphia. During the course of the robbery, one of Reid’s coconspirators [Dwayne Bennett] shot and killed Janke. Following a jury trial, Reid was convicted of second-degree murder and related offenses and sentenced to the mandatory sentence of life without the possibility of parole for second-degree murder, plus concurrent terms of years for the related offenses. Reid’s convictions and sentences were affirmed on direct appeal, see Commonwealth v. Reed, 1 643 A.2d 707 (Pa. Super. Ct. 1994) (table), and his initial efforts to obtain post-conviction relief were unsuccessful, see 742 A.2d 1150 (Pa. Super. Ct. 1999) (table). Reid also unsuccessfully sought federal habeas relief in this Court. See Reid v. Vaughn, 279 F. Supp. 2d 636 (E.D. Pa. 2003), aff’d, 109 F. App’x 500 (3d Cir. 2004).

The Supreme Court subsequently held that mandatory life-without- parole [LWOP] sentences violate the Eighth Amendment for people under the age of 18 at the time of their offenses. See Miller v. Alabama, 567 U.S. 460 (2012) and Montgomery v. Louisiana, 577 U.S. 190 (2016). Reid again sought postconviction relief, [Footnote 2: Reid’s second PCRA petition was filed in 2005 and amended in 2009, both before Miller. However, Miller was decided during the pendency of Reid’s appeals to the Superior Court, and the Superior Court remanded for resentencing. See Commonwealth v. Reid, No. 1980 EDA 2014, 2016 WL 1292915 (Pa. Super. Ct. Apr. 1, 2016)] arguing that his sentence was unconstitutional, among other things. The state court denied relief as to Reid’s convictions but vacated his life sentence and ultimately resentenced him to an agreed-upon term of 25 years to life for the second-degree murder conviction, with no further penalty for his related convictions. This disposition made Reid immediately eligible for parole consideration. [Footnote 3: Reid has since been paroled, and he will remain on parole for the rest of his life. See PA. CODE § 63.2.]

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