Robertson v. Lumpkin

CourtDistrict Court, S.D. Texas
DecidedAugust 28, 2025
Docket4:24-cv-02408
StatusUnknown

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

Bluebook
Robertson v. Lumpkin, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT August 28, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

STEVEN RAY ROBERTSON, § TDCJ # 00287929, § § Petitioner, § § VS. § CIVIL ACTION NO. 4:24-2408 § ERIC GUERRERO, § § Respondent. §

MEMORANDUM OPINION AND ORDER

The petitioner, Steven Ray Robertson, is an inmate in the Texas Department of Criminal Justice–Correctional Institutions Division (TDCJ).1 Robertson brings this habeas action under 28 U.S.C. § 2254 to challenge a parole revocation. The respondent filed an answer (Dkt. 60), along with a copy of the state-court records (Dkt. 59), and Robertson responded (Dkt. 62). Robertson also filed a motion to appoint counsel (Dkt. 61), a motion for summary judgment seeking judgment in his favor (Dkt. 63), and a motion to expedite these proceedings (Dkt. 64). Having considered the pleadings, the briefing, the applicable law, and all matters of record, the Court will dismiss the petition and deny Robertson’s motion for summary judgment for the reasons explained below. His other motions will be denied as moot.

1 Bobby Lumpkin previously was the named respondent in this action. Eric Guerrero has succeeded Lumpkin as Director of TDCJ. Under Rule 25(d) of the Federal Rules of Civil Procedure, Guerrero is automatically substituted as a party. I. BACKGROUND Robertson is serving a life sentence in TDCJ based on a 1979 conviction in Harris County for aggravated robbery, enhanced, in Cause No. 281541 (Dkt. 59-1, at 74; see

Inmate Information Search, available at https://inmate.tdcj.texas.gov/InmateSearch/ (last visited Aug. 27, 2025). In this habeas action, he does not challenge his conviction, but rather alleges violations of his rights during revocation proceedings before the Board of Pardons and Paroles (Board). Robertson initiated this proceeding in March 2023 in the Eastern District of Texas, filing a petition (Dkt. 1), an amended petition (Dkt. 6), and a

second amended petition (Dkt. 40). On June 11, 2024, the court in the Eastern District of Texas transferred the case to this Court (Dkt. 42), and this Court instructed the respondent to answer. In May 2024, after initiating this federal action, Robertson filed an application for state habeas relief challenging his parole revocation and raising seven grounds for relief

(Dkt. 59-1, at 5-22) (WR-10,254-05). On June 5, 2024, the trial court recommended denial of habeas relief (Dkt. 59-1, at 43-45). On July 31, 2024, the Court of Criminal Appeals construed the writ as raising a due process claim and remanded for relevant findings (Dkt. 59-3). On remand, the trial court obtained relevant records and affidavits from Lauren Montgomery, Section Director for Review and Release Processing for TDCJ’s parole

division, and Charley Valdez, Program Supervisor V for TDCJ’s classifications and records department. See Dkt. 59-4, at 18-23 (Montgomery Affidavit); id. at 188-91 (Valdez Affidavit). On September 23, 2024, the court entered findings of fact and conclusions of law (id. at 370-77) recommending denial of relief. On October 30, 2024, the Court of Criminal Appeals denied habeas relief without written order on the findings of the trial court and the court’s independent review of the record (Dkt. 59-6). The record in this action includes the Montgomery affidavit, executed on September

5, 2024. Montgomery stated that Robertson was convicted in Harris County in Cause No. 281541 in 1979 and sentenced to life in prison; that he was released to supervision on February 23, 2010; that the Board revoked his supervision on August 10, 2023; and that, at the time of her affidavit, he was in TDCJ custody serving the remainder of his life sentence (Dkt. 59-4, at 19). Montgomery then responded to specific questions posed by

the state habeas court and provided the following information, with supporting exhibits: • During the revocation process, authorities informed Robertson in writing of the accusations against him, and Robertson signed the notice on March 3, 2023, to demonstrate his receipt (id. at 46; see id. at 25 (notice signed June 14, 2023)). Robertson’s alleged violations were failing to identify himself to police, possession of a controlled substance, failure to participate in sex offender treatment, failure to submit to a polygraph, and failure to pay supervision fees. At a preliminary hearing on March 22, 2023, the hearing officer sustained each of the allegations and decided that Robertson’s case would to proceed to a revocation hearing (id. at 30-32).

• At Robertson’s revocation hearing on July 28, 2023, appointed counsel appeared for Robertson. Montgomery states that Robertson “entered the room of the hearing yelling and stating he will not have an attorney represent him” and “made derogatory statements and continued yelling at the hearing officer” (id. at 21). Robertson’s counsel therefore asked for Robertson to be removed so that the hearing could be conducted, and six detention officers removed him (id. at 102).

• Regarding Robertson’s allegation that he had been denied compulsory process of witnesses, subpoena ability, and the right to confront and cross-examine witnesses in person, Montgomery stated that Robertson had been removed from the hearing “due to his behavior” and at the request of his counsel, but was “nevertheless represented by counsel” (id. at 21 (citing id. at 102)). • Regarding Robertson’s allegation that the Board had refused to allow him to enter testimony into the record, Montgomery stated that Robertson had been removed from the hearing but that the Board had considered his testimony from the preliminary hearing (id. at 100-110).

• Based on evidence presented at the revocation hearing, the Board sustained violations by Robertson, in particular, failure to identify himself to police (Rule 2), possession of a controlled substance (Rule 2), failure to participate in sex offender treatment (Rule 8X), and failure to pay supervision fees (Rule 9C) (id. at 96-99).

• The Board of voted to revoke Robertson’s parole on August 10, 2023 (id. at 98). The next day, Robertson signed a receipt for the results of the hearing (id. at 184).

(Dkt. 59-4, at 20-22). The state habeas record also contains a certificate of parole demonstrating that Robertson agreed, when he accepted his release to parole in 2010, that his release was subject to enumerated conditions and could be revoked for “a violation or refusal to comply with any of the conditions of supervision” (Dkt. 59-4, at 52 (certificate of parole signed by Robertson on Feb. 23, 2010)). In his federal habeas petition, Robertson brings ten claims for relief: 1. The respondent violated the Supremacy Clause and Separation of Powers Clause during revocation proceedings;

2. The rules and guidelines regarding parole are unconstitutionally vague and ambiguous;

3. The respondent’s implementation of parole rules is ultra vires of the Texas Administrative Procedures Act and the federal and state constitutions;

4. The respondent enforces parole rules in an arbitrary and capricious manner;

5. The respondent violated his Fourth Amendment right to privacy and to be free from warrantless search and seizures; 6. The respondent violated his Eighth Amendment rights in connection with denial of bond;

7. The respondent violated his Sixth Amendment rights during parole revocation proceedings when officials refused to inform him of the nature and cause of the charges against him, to allow to him represent himself, to confront and cross- examine witnesses, to compel testimony on his behalf, or to issue subpoenas;

8.

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Robertson v. Lumpkin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robertson-v-lumpkin-txsd-2025.