Rodriguez v. Henley

District Court, D. Nevada·Decided July 31, 2025·No. 3:24-cv-00182·Unknown

Opinion

* * *

JEFFREY RODRIGUEZ, Case No. 3:24-cv-00182-MMD-CLB

Petitioner, ORDER v.

JOHN HENLEY, et al.,

Respondents.

Petitioner Jeffrey Rodriguez, a Nevada prisoner, has filed a pro se Petition for a Writ of Habeas Corpus under 28 U.S.C. § 2254. (ECF No. 7 (“Petition”).) Before the Court is Respondents’ motion to dismiss the Petition. (ECF No. 28 (“Motion”).) Rodriguez opposed the Motion, and Respondents replied. (ECF Nos. 33, 40.) For the reasons discussed below, the Court grants the Motion in part. A jury found Rodriguez guilty of (1) the murder of his wife with the use of a deadly weapon, (2) three counts of assault with a deadly weapon for shooting at bystanders who had stopped to help, and (3) being a felon in possession of a firearm. (ECF No. 22-12.) Rodriguez was sentenced to (1) life with the possibility of parole after 20 years for the murder conviction with a consecutive sentence of 72 to 180 months for the deadly weapon enhancement, (2) consecutive terms of 24 to 60 months for each of the assault convictions, and (3) a concurrent term of 12 to 60 months for the felon in possession of a firearm conviction. (Id.) Rodriguez appealed, and the Nevada Supreme Court affirmed on December 18, 2015. (ECF No. 22-37.) Rodriguez filed a state habeas petition on February 2, 2017. (ECF No. 22-43.) The state court denied the petition on March 20, 2023. (ECF No. 24-13.) Rodriguez appealed, and the Nevada Court of Appeals affirmed on March 25, 2024. (ECF No. 24-35.) Remittitur issued on April 29, 2024. (ECF No. 24-37.) Rodriguez commenced this instant action on or about April 23, 2024. (ECF No. 1.) The Court conducted an initial review of the Petition and ordered that it be served on Respondents. (ECF No. 6.) Rodriguez raises the following grounds in his Petition:

1. His trial counsel failed to provide continuous representation at all stages of the trial process. 2. His trial counsel failed to investigate and prepare for trial. 3. His trial counsel failed to call, secure, or subpoena any witnesses for trial, including (a) Edgar Rodriguez, (b) defending against the prosecutor’s testimony, and (c) Martha Mahaffey, PhD. 4. His trial counsel failed to impeach prosecution witnesses. 5. His trial counsel failed to object to fabricated evidence presented by the prosecution. 6. His trial counsel misstated key facts in his closing argument. 7. His trial counsel’s advice deprived him of his right to testify due to (a) his waiver of his right to testify not being knowingly made and (b) his decision was impaired by the levels of Depakote in his system. 8. His trial counsel failed to lodge a sufficient objection to the admission of highly prejudicial character evidence. 9. His appellate counsel was ineffective. 10. The prosecution committed misconduct. 11. There was judicial misconduct, including (a) not granting a continuance of the trial, (b) allowing prejudicial character evidence that he was a sex offender to be admitted at trial, (c) being subjective towards the jury panel during voir dire, and (d) showing favoritism towards the prosecution. 12. He was incompetent during his trial. 13. There was insufficient evidence to support his first-degree murder conviction; instead, there was only sufficient evidence to prove voluntary manslaughter. 14. The cumulative errors of grounds 1 through 13 warrant the granting of relief.1 (ECF No. 7.)

1Respondents read the Petition as also including grounds 15 and 16. (See ECF No. 28 at 4.) However, these grounds, in which Respondents argue that Rodriguez is alleging that the state court erred in its post-conviction decision and that his post- conviction counsel provided ineffective assistance of counsel, appear to be general arguments rather than stated grounds for relief. Rodriguez confirmed this in his reply brief. (ECF No. 33 at 19.) 2 Respondents argue that (1) only grounds 3c and 7a are exhausted, (2) the Court should not consider any new evidence, (3) grounds 11, 13, and 14 are not cognizable, and (4) the due process claims are conclusory. (ECF No. 28.) The Court will address these arguments in turn. A. Exhaustion Respondents argue that only grounds 3c and 7a are exhausted, so the remaining grounds should be dismissed as unexhausted. (ECF No. 28 at 5-12.) A state prisoner must exhaust state court remedies on habeas claims before presenting those claims to the federal courts. 28 U.S.C. § 2254(b)(1)(A). This exhaustion requirement ensures that the state courts, as a matter of comity, will have the first opportunity to address and correct alleged violations of federal constitutional guarantees. See Coleman v. Thompson, 501 U.S. 722, 730-31 (1991). “A petitioner has exhausted his federal claims when he has fully and fairly presented them to the state courts.” Woods v. Sinclair, 764 F.3d 1109, 1129 (9th Cir. 2014). 1. Grounds 1, 2, 3a, 3b, 4, 5, 6, 7b, and 8 Rodriguez acknowledges that grounds 1, 2, 3a, 3b, 4, 5, 6, 7b, and 8 are unexhausted, but he asserts that these grounds are technically exhausted and procedurally defaulted and that he can overcome the procedural defaults under Martinez v. Ryan2. (ECF No. 33 at 4.) A claim may be considered procedurally defaulted if “it is clear that the state court would hold the claim procedurally barred.” Sandgathe v. Maass, 314 F.3d 371, 376 (9th Cir. 2002). Rodriguez would face several procedural bars if he were to return to state court. See, e.g., NRS §§ 34.726, 34.810. Nevada has cause and prejudice and fundamental miscarriage of justice exceptions to its procedural bars, which are

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