Ryle v. May

CourtDistrict Court, D. Delaware
DecidedSeptember 13, 2023
Docket1:20-cv-00910
StatusUnknown

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

Bluebook
Ryle v. May, (D. Del. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

ALEX RYLE, ) ) Petitioner, ) ) v. ) C.A. No. 20-910 (MN) ) ROBERT MAY, Warden, and ) ATTORNEY GENERAL OF THE STATE ) OF DELAWARE, ) ) Defendant. )

MEMORANDUM OPINION

Alex Ryle – Pro se Petitioner.

Elizabeth R. McFarlan, Deputy Attorney General, Delaware Department of Justice, Wilmington, DE – Attorney for Respondents.

September 13, 2023 Wilmington, Delaware NOREIKA, U.S. DISTRICT JUDGE Pending before the Court is a Petition for a Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2254 (“Petition”) filed by Petitioner Alex Ryle (“Petitioner”). (D.I. 1; D.I. 3). The State filed an Answer in opposition, to which Petitioner filed a Reply. (D.I. 13; D.I. 17). For the reasons discussed, the Court will deny the Petition. I. BACKGROUND On April 12, 2014, police arrested [Petitioner] for evading probation authorities. When the police searched [Petitioner] incident to his arrest, they found a handgun loaded with nine rounds of ammunition. At the time of his arrest, [Petitioner] was a person prohibited from possessing a gun because of prior convictions. Ryle v. State, 149 A.3d 505 (Table), 2016 WL 5929952, at *1 (Del. Oct. 11, 2016). Petitioner was questioned at the police station and confessed to possessing the gun in a post-Miranda recorded interview. Jd. In July 2014, a New Castle County grand jury returned an indictment charging Petitioner with three counts of possession of a firearm by a person prohibited (“PFBPP”), possession of ammunition by a person prohibited (“PABPP”), carrying a concealed deadly weapon (““CCDW”), and illegal possession of a controlled substance. (D.I. 12-1 at Entry No. 2; D.I. 12-10 at 64-67). In December 2014, a New Castle County grand jury returned a superseding indictment that modified the language in the charges but did not add or remove any charged offenses. (D.I. 12-1 at Entry No. 22; D.I. 12-10 at 186-189). Before trial on February 10, 2015, the State dismissed two counts of PFBPP and the single count of illegal possession of a controlled substance. (D.I. 13 at 2). Petitioner represented himself at trial. On February 11, 2015, a Superior Court jury found Petitioner guilty of one count each of PFBPP, PABPP, and CCDW. The Superior Court revoked Petitioner’s bail, ordered a presentence investigation, and committed Petitioner to the custody of the Department of Correction pending sentencing. On February 19, 2015, Petitioner moved for a

new trial, which the Superior court denied on August 14, 2015. See State v. Ryle, 2015 WL 5004903 (Del. Super. Ct. Aug. 15, 2015). On October 5, 2015, the Superior Court sentenced Petitioner as a habitual offender to twenty-three years of imprisonment for his PFBPP and CCDW convictions. For his PABPP

conviction, the Superior Court sentenced Petitioner to eight years of incarceration, suspended for decreasing levels of supervision. (D.I. 12-5 at 17-22). Petitioner appealed, and the Delaware Supreme Court affirmed Petitioner’s convictions and sentences on October 11, 2016. See Ryle, 2016 WL 5929952 at *4. On August 16, 2017, Petitioner filed a pro se motion for postconviction relief pursuant to Delaware Superior Court Criminal Rule 61 (“Rule 61 motion”) and a motion for the appointment of counsel. (D.I. 12-10 at 22-26). The Superior Court granted the motion to appoint counsel and, on May 23, 2018, appointed postconviction counsel filed a motion to withdraw on the ground that there were no meritorious postconviction claims. (D.I. 12-1 at Entry No. 94; D.I. 12-11 at 227- 228; D.I. 12-15 at 83-106). Petitioner supplemented his claims. (D.I. 12-16 at 66-75). On

June 27, 2019, a Superior Court Commissioner issued a Report and Recommendation that Petitioner’s Rule 61 motion be denied. (D.I. 12-15 at 51-73); see State v. Ryle, 2019 WL 2714817 at *4 (Del. Super. Ct. June 27, 2019). On October 21, 2019, the Superior Court adopted the Commissioner’s Report and Recommendation, granted postconviction counsel’s motion to withdraw, and denied Petitioner’s Rule 61 motion. See Ryle, 2019 WL 5306847, at *4 (Del. Super. Ct. Oct. 21, 2019). The Delaware Supreme Court affirmed that decision on May 5, 2020. See Ryle v. State, 228 A.3d 1064 (Table), 2020 WL 2188923 (Del. May 5, 2020). II. GOVERNING LEGAL PRINCIPLES A. The Antiterrorism and Effective Death Penalty Act of 1996 Congress enacted the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”) “to reduce delays in the execution of state and federal criminal sentences . . . and to further the principles of comity, finality, and federalism.” Woodford v. Garceau, 538 U.S. 202, 206 (2003). Pursuant to AEDPA, a federal court may consider a habeas petition filed by a state prisoner only

“on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a). AEDPA imposes procedural requirements and standards for analyzing the merits of a habeas petition in order to “prevent federal habeas ‘retrials’ and to ensure that state-court convictions are given effect to the extent possible under law.” Bell v. Cone, 535 U.S. 685, 693 (2002). B. Exhaustion and Procedural Default Absent exceptional circumstances, a federal court cannot grant habeas relief unless the petitioner has exhausted all means of available relief under state law. See 28 U.S.C. § 2254(b); O’Sullivan v. Boerckel, 526 U.S. 838, 842-44 (1999); Picard v. Connor, 404 U.S. 270, 275 (1971). AEDPA states, in pertinent part:

An application for a writ of habeas corpus on behalf of a person in custody pursuant to the judgment of a State court shall not be granted unless it appears that –

(A) the applicant has exhausted the remedies available in the courts of the State; or

(B)(i) there is an absence of available State corrective process; or (ii) circumstances exist that render such process ineffective to protect the rights of the applicant.

28 U.S.C. § 2254(b)(1). The exhaustion requirement is based on principles of comity, requiring a petitioner to give “state courts one full opportunity to resolve any constitutional issues by invoking one complete round of the State’s established appellate review process.” O’Sullivan, 526 U.S. at 844-45; Werts v. Vaughn, 228 F.3d 178, 192 (3d Cir. 2000). A petitioner satisfies the exhaustion requirement by

demonstrating that the habeas claims were “fairly presented” to the state’s highest court, either on direct appeal or in a post-conviction proceeding, in a procedural manner permitting the court to consider the claims on their merits. See Bell v. Cone, 543 U.S. 447, 451 n.3 (2005); Castille v. Peoples, 489 U.S. 346, 351 (1989). A petitioner’s failure to exhaust state remedies will be excused, and the claims treated as “technically exhausted”, if state procedural rules preclude him from seeking further relief in state courts. See Coleman v. Thompson, 501 U.S. 722, 732, 750-51 (1991) (such claims “meet[] the technical requirements for exhaustion” because state remedies are no longer available); see also Woodford v. Ngo, 548 U.S. 81, 92-93 (2006). Although treated as technically exhausted, such claims are procedurally defaulted for federal habeas purposes. See Coleman, 501 U.S.

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Ryle v. May, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ryle-v-may-ded-2023.