Shay v. Wahl

CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 19, 2025
Docket3:22-cv-01157
StatusUnknown

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

Bluebook
Shay v. Wahl, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA ERIC W. SHAY, Civil No. 3:22-cv-1157 Petitioner (Judge Mariani) V, SUPERINTENDENT WAHL, et al., : Respondents MEMORANDUM Petitioner Eric Shay (“Shay”) filed the instant petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254 challenging a judgment and conviction imposed in the Court of Common Pleas of Lackawanna County, Pennsylvania. (Doc. 1). For the reasons set forth below, the Court will deny the habeas petition and a certificate of appealability will not issue. Background’ On February 4, 2015, the Commonwealth of Pennsylvania filed a criminal complaint charging Shay with various offenses relating to his attempt to meet a minor for sex via the

1 A federal habeas court may take judicial notice of state court records. See Zedonis v. Lynch, 233 F. Supp.3d 417, 422 (M.D. Pa. 2017) (Caldwell, J.) (citing Pension Benefit Guar. Corp. v. White Consul. Indus., Inc., 998 F.2d 1192, 1197 (3d Cir. 1993) and Dean v. Copozza, No. Civ. A. 13-41, 2013 WL 1787804, at *1 (W.D. Pa. Apr. 10, 2013) (“Pennsylvania’s Unified Judicial System provides online access to the docket sheets for criminal cases, and this Court may take judicial notice of those public dockets.”). Accordingly, in reviewing this petition, the Court takes judicial notice of the publicly available dockets of criminal and collateral post-conviction proceedings in the Court of Common Pleas of Lackawanna County, the Pennsylvania Superior Court, and the Pennsylvania Supreme Court.

internet. Commonwealth v. Shay, No. CP-35-CR-0000276-2015 (Pa. Ct. Com. PI. Lackawanna Cnty.). On February 17, 2016, following a jury trial, Shay was convicted of one count of unlawful contact with a minor, one count of criminal attempt to commit involuntary deviate sexual intercourse, one count of criminal attempt to commit indecent assault, one count of unlawful contact with a minor to transmit obscene material to a minor, and one count of criminal use of a communications facility. /d. On June 29, 2016, the trial court imposed an aggregate sentence of 6% to 19 years’ imprisonment. Id. Shay did not file a direct appeal. /d. On April 11, 2017, counsel filed a petition for post-conviction collateral relief pursuant to the Post Conviction Relief Act (“PCRA”), 42 Pa. Cons. STAT. §§ 9541-46, seeking reinstatement of Shay’s appellate rights nunc pro tunc. Id. On August 1, 2017, the PCRA court granted the petition. /d. On September 18, 2018, the Pennsylvania Superior Court affirmed the judgment of sentence. Commonwealth v. Shay, No. 1385 MDA 2017, 2018 WL 4442972 (Pa. Super. Sept. 18, 2018). On March 12, 2019, the Pennsylvania Supreme Court denied Shay’s petition for allowance of appeal. Commonwealth v. Shay, No. 696 MAL 2018 (Pa. March 12, 2019). On August 19, 2019, Shay filed a pro se PCRA petition. (Doc. 16-7, at 6-79). Counsel was appointed to represent Shay, and counsel subsequently filed a motion to withdraw and a no-merit letter. (Doc. 16-7, at 89-98). On December 16, 2019, Shay filed a

pro se amended PCRA petition. (Doc. 16-7, at 100-166). On February 4, 2020, the PCRA

court issued a notice of its intent to dismiss Shay’s petition without a hearing and granted counsel’s motion to withdraw. (Doc. 16-7, at 168-78). On March 18, 2020, the PCRA court denied Shay’s petition. (Doc. 16-8, at 35). On November 22, 2021, the Pennsylvania Superior Court affirmed the denial of PCRA relief. Commonwealth v. Shay, No. 714 MDA 2020, 2021 WL 5443669 (Pa. Super. Nov. 22, 2021). Shay did not file a petition for allowance of appeal with the Pennsylvania Supreme Court. On February 22, 2022, Shay filed a second pro se PCRA petition. (Doc. 16-9, at 94- 156). On May 18, 2022, the PCRA court dismissed the second petition as untimely. (Doc. 16-10, at 33). Shay did not appeal from the dismissal of his second PCRA petition. Thereafter, Shay timely filed the instant petition pursuant to 28 U.S.C. § 2254. (Doc. 1). ll. | Habeas Claims Presented for Federal Review Shay seeks habeas relief based on the following grounds: e Ground One: Did the trial court abuse its discretion in sustaining the Commonwealth’s objection based upon improper characterization of evidence?

e Ground Two: Did the trial court abuse its discretion when it failed to adopt jury instructions proposed by trial counsel on the definition of “attempt”?

e Ground Three: Was trial counsel ineffective for failing to raise the entrapment defense[?] o Shay seeks to amend Ground Three as follows: Petitioner's Sixth and Fourteenth Amendment right[s] under the U.S. Constitution and his rights under Article 1, Section 9 of the Pennsylvania Constitution were violated when [t]rial [clounsel provided ineffective assistance of counsel in failing to conduct an investigation and never developed a defense strategy at trial.

(Doc. 1, at 25-26, 28; Doc. 49, at 11). lll. Legal Standards The statutory authority of federal courts to issue habeas corpus relief for persons in state custody is provided by 28 U.S.C. § 2254, as amended by the Antiterrorism and Effective Death Penalty Act of 1996 (‘AEDPA”). A habeas corpus petition pursuant to § 2254 is the proper mechanism for a prisoner to challenge the “fact or duration” of his confinement. Preiser v. Rodriguez, 411 U.S. 475, 498-99, 93 S.Ct. 1827, 36 L.Ed.2d 439 (1973). “[I]t is not the province of a federal habeas court to reexamine state-court determinations on state-law questions.” Estelle v. McGuire, 502 U.S. 62, 67-68, 112 S.Ct. 475, 116 L.Ed.2d 385 (1991). Rather, federal habeas review is restricted to claims based “on the ground that [petitioner] is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a); Estelle, 502 U.S. at 68. A. — Exhaustion and Procedural Default A habeas petitioner must exhaust state court remedies before obtaining habeas relief. 28 U.S.C. § 2254(b)(1)(A). The traditional way to exhaust state court remedies in Pennsylvania was to fairly present a claim to the trial court, the Pennsylvania Superior Court, and the Pennsylvania Supreme Court. See Evans v. Court of Common Pleas, Delaware County, 959 F.2d 1227, 1230 (3d Cir. 1992). However, in light of Pennsylvania Supreme Court Order No. 218, issued May 9, 2000, (“Order No. 218”), it is no longer necessary for Pennsylvania inmates to seek allocatur from the Pennsylvania Supreme

Court in order to exhaust state remedies under 28 U.S.C. § 2254(c). See Lambert v. Blackwell, 387 F.3d 210, 233-34 (3d Cir. 2004) (“We now hold that Order No. 218 renders review from the Pennsylvania Supreme Court ‘unavailable’ for purposes of exhausting state court remedies under § 2254(c).”).2. The habeas petitioner has the burden of proving exhaustion. Lambert v. Blackwell, 134 F.3d 506, 513 (3d Cir. 1997). A petitioner's failure to exhaust his state remedies may be excused in limited circumstances on the ground that exhaustion would be futile.

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Bluebook (online)
Shay v. Wahl, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shay-v-wahl-pamd-2025.