Rhomer v. Lumpkin - TDCJ Director

CourtDistrict Court, W.D. Texas
DecidedMarch 17, 2022
Docket5:21-cv-00047
StatusUnknown

This text of Rhomer v. Lumpkin - TDCJ Director (Rhomer v. Lumpkin - TDCJ Director) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rhomer v. Lumpkin - TDCJ Director, (W.D. Tex. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

WILLIAM RHOMER, § TDCJ No. 02039278, § § Petitioner, § § v. § CIVIL NO. SA-21-CA-0047-XR § BOBBY LUMPKIN, Director, § Texas Department of Criminal Justice, § Correctional Institutions Division, § § Respondent. §

MEMORANDUM OPINION AND ORDER Before the Court are Petitioner William Rhomer’s Petition for Writ of Habeas Corpus pursuant to 28 U.S.C. § 2254 (ECF No. 1), Petitioner’s Memorandum in Support (ECF No. 4), and Respondent Bobby Lumpkin’s Answer thereto (ECF No. 9). Petitioner challenges the constitutionality of his state court felony murder conviction, arguing that his trial counsel was ineffective and that the State presented false testimony at his trial. Having reviewed the record and pleadings submitted by both parties, the Court concludes Petitioner is not entitled to relief under the standards prescribed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). See 28 U.S.C. § 2254(d). Petitioner is also denied a certificate of appealability. I. Background The facts of Petitioner’s case were accurately summarized by the Texas Court of Criminal Appeals: [Petitioner] left a bar shortly before 3:00 a.m. and drove his car eastbound on Nakoma Drive. The decedent, Gilbert Chavez, was riding his motorcycle in the westbound lane of Nakoma Drive. As both [Petitioner] and Chavez approached the intersection of Nakoma Drive and Colwick Street from opposite directions, the vehicles collided. Mario Negron and Kenneth Ferrer testified that they were driving in the westbound lane of Nakoma Drive around 3:00 a.m. when they came upon the accident. Both testified to driving through the debris of the accident.

Negron and Ferrer saw Chavez was badly injured and lying near his motorcycle, and they called for help. They saw [Petitioner] at the scene stumbling near his car which had crashed into a building. When police officers arrived, [Petitioner] told them that Chavez had driven into his lane of traffic; he later told one of the officers that Chavez had pulled out in front of him as if Chavez had been traveling in the same direction as [Petitioner] and had hit [Petitioner] on the right side.

Chavez was taken to the hospital where he later died from his injuries. Dr. Randy Frost, the Bexar County Chief Medical Examiner, testified the injuries were consistent with an automobile accident, and multiple traumatic blunt force injuries were the cause of death.

Rhomer v. State, 569 S.W.3d 664, 667 (Tex. Crim. App. 2019); (ECF No. 8-30). After hearing all the evidence, a Bexar County jury found Petitioner guilty of felony murder (enhanced as a repeat offender) and sentenced him to seventy-five years of imprisonment.1 State v. Rhomer, No. 2012-CR-9066 (290th Dist. Ct., Bexar Cnty., Tex. Dec. 8, 2015); (ECF No. 8-15 at 289-90). The Texas Fourth Court of Appeals affirmed Petitioner’s conviction in a published opinion on direct appeal. Rhomer v. State, 522 S.W.3d 13 (Tex. App.─San Antonio, Apr. 12, 2017, pet. granted Nov. 8, 2017); (ECF No. 8-16). After granting Petitioner’s petition for discretionary review and hearing oral argument, the Texas Court of Criminal Appeals affirmed the judgment of the court of appeals in a published opinion delivered January 30, 2019. Rhomer, 569 S.W.3d at 672; (ECF No. 8-30). Thereafter, Petitioner filed a state habeas corpus

1 Petitioner had actually been convicted on three counts that were alleged in the indictment—felony murder, intoxication manslaughter, and manslaughter. (ECF No. 8-15 at 272-74). But in its final judgment, the trial court abandoned counts two and three and sentenced Petitioner to seventy-five years on count one only.

2 application challenging the constitutionality of his state court conviction, but the Texas Court of Criminal Appeals eventually denied the application without written order based on the findings of the trial court and on the court’s own independent review of the record. Ex parte Rhomer, No. 91,161-01 (Tex. Crim. App.); (ECF Nos. 8-31, 8-35 at 4-22).

Petitioner initiated the instant proceedings on January 20, 2021, by filing a petition for federal habeas corpus relief. (ECF No. 1). In the petition and supplemental memorandum that followed, Petitioner raises the same two grounds for relief that were rejected by the Texas Court of Criminal Appeals during his state habeas proceedings: namely, that (1) his trial counsel rendered ineffective assistance by failing to consult an expert in accident reconstruction, and (2) the State relied on false testimony to obtain a conviction. II. Standard of Review Petitioner’s federal habeas petition is governed by the heightened standard of review provided by the AEDPA. 28 U.S.C.A. § 2254. Under § 2254(d), a petitioner may not obtain federal habeas corpus relief on any claim that was adjudicated on the merits in state court

proceedings unless the adjudication of that claim either: (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 proceeding. Brown v. Payton, 544 U.S. 133, 141 (2005). This intentionally difficult standard stops just short of imposing a complete bar on federal court relitigation of claims already rejected in state proceedings. Harrington v. Richter, 562 U.S. 86, 102 (2011) (citing Felker v. Turpin, 518 U.S. 651, 664 (1996)). 3 A federal habeas court’s inquiry into unreasonableness should always be objective rather than subjective, with a focus on whether the state court’s application of clearly established federal law was “objectively unreasonable” and not whether it was incorrect or erroneous. McDaniel v. Brown, 558 U.S. 120 (2010); Wiggins v. Smith, 539 U.S. 510, 520-21

(2003). Even a strong case for relief does not mean the state court’s contrary conclusion was unreasonable, regardless of whether the federal habeas court would have reached a different conclusion itself. Richter, 562 U.S. at 102. Instead, a petitioner must show that the decision was objectively unreasonable, which is a “substantially higher threshold.” Schriro v. Landrigan, 550 U.S. 465, 473 (2007); Lockyer v. Andrade, 538 U.S. 63, 75-76 (2003). So long as “fairminded jurists could disagree” on the correctness of the state court’s decision, a state court’s determination that a claim lacks merit precludes federal habeas relief. Richter, 562 U.S. at 101 (citing Yarborough v. Alvarado, 541 U.S. 652, 664 (2004)). In other words, to obtain federal habeas relief on a claim previously adjudicated on the merits in state court, Petitioner must show that the state court’s ruling “was so lacking in justification that there was an error well

understood and comprehended in existing law beyond any possibility for fairminded disagreement.” Id. at 103; see also Bobby v. Dixon, 565 U.S. 23, 24 (2011). III. Merits Analysis A. Trial Counsel (Claim 1). In his first claim for relief, Petitioner contends that his trial counsel rendered ineffective assistance by failing to consult an expert in accident reconstruction to challenge the testimony of the State’s expert, Detective John Doyle.

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