Richards v. Hildebrand

CourtDistrict Court, S.D. Ohio
DecidedOctober 2, 2024
Docket2:23-cv-03544
StatusUnknown

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

Bluebook
Richards v. Hildebrand, (S.D. Ohio 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

KENDALL K. RICHARDS,

Petitioner, : Case No. 2:23-cv-3544 Consolidated with 2:23-cv-2595

- vs - District Judge Algenon L. Marbley Magistrate Judge Michael R. Merz

JENNY HILDEBRAND, Warden,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case under 28 U.S.C. § 2254 was brought by Petitioner Kendall Richards with the assistance of counsel. On Respondent’s Motion (ECF No. 7) and with the consent of Petitioner (ECF No. 8), Petitioner’s pro se habeas Petition challenging the same conviction (Case No. 2:23-cv-2595) was consolidated with this case (ECF No. 9) and Petitioner filed an Amended Petition (ECF No. 10) which is now the operative pleading. In response to the Amended Petition, Respondent filed the State Court Record (ECF No. 11), trial transcripts (ECF No. 12), and a Return of Writ (ECF No. 13). Petitioner then filed his Traverse (ECF No. 16) in which he has withdrawn his First, Third, and Fourth Grounds for Relief. Id. at PageID 866. On September 30, 2024, the Magistrate Judge reference in this case was transferred to the undersigned to help balance the Magistrate Judge workload in the District (ECF No. 17). As pleaded in the Amended Petition, Richards’ Second Ground for Relief reads: Ground Two: Ineffective Assistance of Appellate Counsel

Supporting Facts: Appellate Counsel’s decision to voluntarily dismiss Petitioner’s timely-filed appeal and subsequently file an untimely appeal has deprived Petitioner of any meaningful opportunity for appellate review.

(ECF No. 10, PageID 63). Respondent does not dispute that this claim is a constitutional claim cognizable in federal habeas corpus. However, Respondent does assert this claim is procedurally defaulted in two ways: first, that it was untimely filed and second, that the claim was not exhausted by appeal to the Supreme Court of Ohio (Return, ECF No. 13, PageID 843-44). Petitioner concedes that his Application to Reopen under Ohio R. App. P. 26(B) was untimely (Traverse, ECF No. 16, PageID 868). However, he contends that the Fourth District Court of Appeals did not decide the 26(B) Application on that basis, but rather found it was without merit. Id. at PageID 868-69.

Analysis

The Sixth Amendment entitles a criminal defendant to the effective assistance of counsel in his or her defense. Evitts v. Lucey, 469 U.S. 387 (1985); Penson v. Ohio, 488 U.S. 75 (1988); Mahdi v. Bagley, 522 F.3d 631, 636 (6th Cir. 2008). The governing standard for effective assistance was enunciated in Strickland v. Washington, 466 U.S. 668 (1984): A convicted defendant's claim that counsel's assistance was so defective as to require reversal of a conviction or death sentence has two components. First, the defendant must show that counsel's performance was deficient. This requires showing that counsel was not functioning as the "counsel" guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel's errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable. Unless a defendant makes both showings, it cannot be said that the conviction or death sentence resulted from a breakdown in the adversary process that renders the result unreliable.

466 U.S. at 687. In other words, to establish ineffective assistance, a defendant must show both deficient performance and prejudice. Berghuis v. Thompkins, 560 U.S. 370, 389 (2010), citing Knowles v. Mirzayance, 556 U.S.111 (2009). The Strickland standard applies on appeal as well as at trial. Smith v. Robbins, 528 U.S. 259, 285 (2000); Burger v. Kemp, 483 U.S. 776 (1987). The procedural default doctrine in habeas corpus is described by the Supreme Court as follows: In all cases in which a state prisoner has defaulted his federal claims in state court pursuant to an adequate and independent state procedural rule, federal habeas review of the claims is barred unless the prisoner can demonstrate cause of the default and actual prejudice as a result of the alleged violation of federal law; or demonstrate that failure to consider the claims will result in a fundamental miscarriage of justice.

Coleman v. Thompson, 501 U.S. 722, 750 (1991); see also Simpson v. Jones, 238 F.3d 399, 406 (6th Cir. 2000). That is, a petitioner may not raise on federal habeas a federal constitutional rights claim he could not raise in state court because of procedural default. Wainwright v. Sykes, 433 U.S. 72 (1977); Engle v. Isaac, 456 U.S. 107, 110 (1982). “Absent cause and prejudice, ‘a federal habeas petitioner who fails to comply with a State’s rules of procedure waives his right to federal habeas corpus review.’” Boyle v. Million, 201 F.3d 711, 716 (6th Cir. 2000), quoting Gravley v. Mills, 87 F.3d 779, 784-85 (6th Cir. 1996); Murray v. Carrier, 477 U.S. 478, 485 (1986); Engle, 456 U.S. at 110; Wainwright, 433 U.S. at 87. [A] federal court may not review federal claims that were procedurally defaulted in state court—that is, claims that the state court denied based on an adequate and independent state procedural rule. E.g., Beard v. Kindler, 558 U.S. 53, 55, 130 S.Ct. 612, 175 L.Ed.2d 417 (2009). This is an important “corollary” to the exhaustion requirement. Dretke v. Haley, 541 U.S. 386, 392, 124 S.Ct. 1847, 158 L.Ed. d 659 (2004). “Just as in those cases in which a state prisoner fails to exhaust state remedies, a habeas petitioner who has failed to meet the State’s procedural requirements for presenting his federal claims has deprived the state courts of an opportunity to address” the merits of “those claims in the first instance.” Coleman [v. Thompson], 501 U.S. [722,] 731-732, 111 S.Ct. 2546, 115 L.Ed.2d 640 [(1991)]. The procedural default doctrine thus advances the same comity, finality, and federalism interests advanced by the exhaustion doctrine. See McCleskey v. Zant, 499 U.S. 467, 493, 111 S.Ct. 1454, 113 L.Ed.2d 517 (1991).

Davila v. Davis, 582 U.S. 521, 527 (2017). As Petitioner acknowledges, the Sixth Circuit Court of Appeals requires a four-part analysis when the State alleges a habeas claim is precluded by procedural default. Barton v. Warden, S. Ohio Corr. Facility, 786 F.3d 450, 464 (6th Cir. 2015), Guilmette v. Howes, 624 F.3d 286, 290 (6th Cir. 2010)(en banc); Eley v. Bagley, 604 F.3d 958, 965 (6th Cir. 2010); Reynolds v. Berry, 146 F.3d 345, 347-48 (6th Cir. 1998), citing Maupin v. Smith, 785 F.2d 135, 138 (6th Cir. 1986); accord Lott v. Coyle, 261 F.3d 594, 601-02 (6th Cir. 2001); Jacobs v.

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Related

Beard v. Kindler
558 U.S. 53 (Supreme Court, 2009)
Wainwright v. Sykes
433 U.S. 72 (Supreme Court, 1977)
County Court of Ulster Cty. v. Allen
442 U.S. 140 (Supreme Court, 1979)
Engle v. Isaac
456 U.S. 107 (Supreme Court, 1982)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Evitts v. Lucey
469 U.S. 387 (Supreme Court, 1985)
Murray v. Carrier
477 U.S. 478 (Supreme Court, 1986)
Burger v. Kemp
483 U.S. 776 (Supreme Court, 1987)
Penson v. Ohio
488 U.S. 75 (Supreme Court, 1988)
Harris v. Reed
489 U.S. 255 (Supreme Court, 1989)
McCleskey v. Zant
499 U.S. 467 (Supreme Court, 1991)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Smith v. Robbins
528 U.S. 259 (Supreme Court, 2000)
Edwards v. Carpenter
529 U.S. 446 (Supreme Court, 2000)
Dretke v. Haley
541 U.S. 386 (Supreme Court, 2004)
Eley v. Bagley
604 F.3d 958 (Sixth Circuit, 2010)
Guilmette v. Howes
624 F.3d 286 (Sixth Circuit, 2010)
George G. Couch v. John Jabe, Warden
951 F.2d 94 (Sixth Circuit, 1991)

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Richards v. Hildebrand, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richards-v-hildebrand-ohsd-2024.