Simpson v. Clarke

CourtDistrict Court, E.D. Virginia
DecidedJanuary 13, 2021
Docket3:20-cv-00298
StatusUnknown

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

Bluebook
Simpson v. Clarke, (E.D. Va. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division JAMES HENRY SIMPSON, Petitioner, Civil Action No. 3:20CV298 DIRECTOR, DEPARTMENT OF CORRECTIONS, Respondent. MEMORANDUM OPINION James Henry Simpson, a Virginia state prisoner proceeding pro se, brings this petition pursuant to 28 U.S.C. § 2254 (“§ 2254 Petition,” ECF No. 6) challenging his 2018 convictions in the Circuit Court of the City of Richmond, Virginia (“Circuit Court”). In his § 2254 Petition, Simpson argues that he is entitled to relief on the following grounds:! Claim One: The Circuit Court violated Simpson’s constitutional rights by “adjudicating [his] case without having subject matter jurisdiction.” (Jd. at 16.)

' In his § 2254 Petition, instead of identifying claims for relief, Simpson indicates that there is “not enough space on this form: (see attached)” for his claims. (See, e.g., ECF No. 6, at 5.) It appears that Simpson stated his eleven claims for relief clearly enough in his attachment. The Court employs the pagination assigned by the CM/ECF docketing system for citations to the parties’ submissions. The Court corrects the capitalization, spacing, and punctuation in quotations from Simpson’s submissions. ? In nearly all of his claims Simpson repeatedly states that the conduct alleged therein violates his Fifth and Fourteenth constitutional rights to process and equal protection under the law. The Fourteenth Amendment states in pertinent part: “No State shall . . . deprive any person of life, liberty, or property, without due process of law. . . nor deny to any person within its jurisdiction the equal protection of the laws.” U.S. Const. amend. XIV, § 1. Simpson fails to explain, and the Court fails to discern, how counsel, who was not a state actor, could violate his Fourteenth Amendment rights. Moreover, none of Simpson’s claims truly implicate the Equal Protection Clause as he fails to identify a similarly situated defendant who was treated differently by the Circuit Court or the Commonwealth. See Morrison vy. Garraghty, 239 F.3d 648, 651 (4th Cir. 2001). Additionally, because Simpson challenges actions by state, not federal actors, his due process claims are governed by the Fourteenth Amendment, not the Fifth Amendment. Accordingly, any equal protection and Fifth Amendment due process claim lack merit and will not be discussed.

Claim Two: The Commonwealth violated Simpson’s due process rights “by knowingly using Officer Michael Poerstel’s false testimony to establish probable cause.” (Id. at 17-18.) Claim Three: The (a) Circuit Court and (b) trial counsel “violated [Simpson’s] Sixth Amendment constitutional right to have a speedy trial.” (Ud. at 19.) Claim Four: The Circuit Court and the Court of Appeals of Virginia violated Simpson’s “4th Amendment constitutional right to be protected against an illegal search and seizure” and his due process rights “by refusing to apply the law to my motion to suppress.” (/d. at 20.) Claim Five: The Circuit Court violated Simpson’s right to due process “by allowing [him] to be convicted of possession of heroin with intent to distribute without a certificate of analysis for the ‘suspected heroin.’” (/d. at 23.) Claim Six: | The Commonwealth violated Simpson’s right to due process “by knowingly using false evidence against [him] to have [him] convicted.” (/d. at 24.) Claim Seven: The Commonwealth violated Simpson’s due process rights “by knowingly using perjured testimony against [him] . . . to have [him] convicted.” (d. at 27.) Claim Eight: The Commonwealth violated Simpson’s due process rights “by suppressing exculpatory evidence . . . at [his] jury trial.” (/d. at 30.) Claim Nine: Trial counsel rendered ineffective assistance “by suppressing exculpatory and impeachable evidence that existed in [his] case that proved that the Commonwealth never had probable cause to charge [him] with any of the crimes.” (/d. at 32-33.) Claim Ten: The Circuit Court violated Simpson’s “right to have effective assistance of counsel by forcing [him] to proceed with an attorney whom [he] was at legal conflict with.” (/d. at 35-36.) Claim Eleven: The Circuit Court violated Simpson’s right “to have counsel by not appointing [him] an attorney and forcing [him] to represent [him]self.” □□□□ at 38.) Claim Twelve: “Chief Justice of the Supreme Court of Virginia . . . violated [his] . . . right to due process . . . by refusing to recuse himself from presiding over [Simpson’s] state habeas corpus.” (/d. at 40.) Respondent moves to dismiss on the ground, inter alia, that Simpson’s claims are either defaulted and barred from review here, are not cognizable on federal habeas review, or lack merit.

Simpson has responded. (ECF No. 14.) For the reasons set forth below, the Motion to Dismiss (ECF No. 10) will be GRANTED, the § 2254 Petition will be DENIED, and the action will be DISMISSED. I. PROCEDURAL HISTORY On February 6, 2017, the grand jury indicted Simpson with possession with intent to distribute heroin, possession of a firearm while possessing with intent to distribute heroin, and possession of a firearm by a convicted felon. Commonwealth v. Lane, No. 17-F-0395, -96, -97 (Va. Cir, Ct. Feb. 6, 2017); (Cir. Ct. Record 21; see id. at 15, 1347).? Upon Simpson’s motion, the Circuit Court bifurcated the trial, separating the possession of a firearm by a convicted felon charge from the other two charges. (Cir. Ct. Record 384.)* After a jury trial, Simpson was convicted of both possession with intent to distribute heroin and possession of a firearm while possessing with intent to distribute heroin. (/d. at 384-85.) The jury also fixed Simpson’s punishment at fifteen years of incarceration. (/d. at 385.) Prior to sentencing, Simpson filed many pro se motions, including a motion to remove his counsel who, at that point, was merely serving as standby counsel for Simpson. (See id. at 542.) Simpson also asked the Circuit Court to appoint him new counsel, permit him to change venue, and set aside the verdict, and he wanted the Circuit Court judge to recuse himself. (See id.) The Court permitted Simpson to argue on his own behalf, then denied

3 The Circuit Court sent the nearly 1500-page criminal record to the Court in the form of a compact disc. Hereinafter, for ease of reference, the Court employs the continuous pagination assigned by the Circuit Court for the cites to the record (“Cir. Ct. Record”). Similarly, the Court employs the continuous pagination assigned by the Supreme Court of Virginia in its citations to that record (“SCVA Record”). 4u: ab a: , . . Nevers Simpson doesnot challenge anything rlefed toh chores hese oe eer □□ at 1.

the motions but relieved counsel from continuing to serve as standby counsel. (/d.) On February 23, 2018, the Circuit Court imposed the fifteen-year-sentence fixed by the jury. (/d. at 542-43). Simpson appealed. On January 3, 2019, the Court of Appeals of Virginia dismissed in part and denied in part the petition for appeal. (/d. at 1267.) On April 3, 2019, a three-judge panel of the Court of Appeals of Virginia again denied the appeal. (/d. at 1284.) Simpson did not file any further direct appeal. On May 6, 2019, Simpson filed a petition for writ of habeas corpus in the Supreme Court of Virginia.’ In his petition, Simpson raised the following claims for relief: Ground 1 The Circuit Court violated his constitutional rights “by adjudicating [his] case without subject matter jurisdiction.” (SCVA Record 6.) Ground 2 The Commonwealth violated Simpson’s due process rights by “knowingly using the arresting officer’s false testimony to establish probable cause.” (id. at 11.) Ground 3 Counsel and the Circuit Court “violated [his] 6th Amendment constitutional right to have a speedy trial.” (/d.

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Bluebook (online)
Simpson v. Clarke, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simpson-v-clarke-vaed-2021.