Singh v. Warden, Noble Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedApril 16, 2025
Docket1:24-cv-00156
StatusUnknown

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

Bluebook
Singh v. Warden, Noble Correctional Institution, (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI TARANPREET SINGH, Petitioner, : Case No. 1:24-cv-156

-vs - District Judge Matthew W. McFarland Magistrate Judge Michael R. Merz WARDEN, Noble Correctional Institution, : Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case was brought by Petitioner Taranpreet Singh pursuant to 28 U.S.C. § 2254 with the assistance of counsel to obtain relief from his convictions for rape, kidnapping, and assault in the Common Pleas Court of Butler County, Ohio (Petition, ECF No. 1). On the Order of Magistrate Judge Caroline H. Gentry, Respondent has filed the State Court Record (ECF No. 4) and a Return of Writ (ECF No. 5). Petitioner has also filed a timely Traverse (ECF No. 9), rendering the case ripe for decision. The Magistrate Judge reference in the case was recently transferred to the undersigned to help balance the Magistrate Judge workload in the District (ECF No. 10). Litigation History

On February 25, 2021, the Butler County grand jury indicted Singh on three counts of rape in violation of Ohio Rev. Code § 2907.02(A)(2) (counts 1, 5, and 7), five counts of kidnapping in violation of Ohio Rev. Code § 2905.01(A)(4) and § 2905.01(A)(3) (counts 2, 3, 6, 8 and 9), and

one count of assault in violation of Ohio Rev. Code § 2903.12(A) (count 4). Counts 7 through 9 contained firearm specifications. (Indictment, State Court Record, ECF No. 4., Ex. 1). A petit jury found Singh guilty of three offenses relating to the victim identified in the Indictment as Jane: rape (count one), kidnapping in violation of Ohio Rev. Code § 2905.01(A)(4) (count three), and assault (count four), but acquitted him on all other charges. Id. at Ex. 7. The trial court sentenced Singh an indefinite prison term of twelve to sixteen years. With the assistance of retained counsel, Singh appealed to the Ohio Twelfth District Court of Appeals raising seven assignments of error (Appellant’s Brief, State Court Record, ECF No. 4, Ex. 9). That court affirmed the conviction. State v. Singh, 2022-Ohio-3385 (Ohio App. 12th Dist.

Sept. 26, 2022). Singh appealed to the Ohio Supreme Court, but that court declined jurisdiction. State v. Singh, 168 Ohio St. 3d 1482 (2022). On March 23, 2024, Singh filed his Petition in this Court, pleading one Ground for Relief: The State of Ohio failed to produce sufficient evidence to convict the Petitioner of the counts in the indictment in violation of his right to due process under the Fifth Amendment made applicable to all state criminal prosecutions by the Fourteenth Amendment to the federal Constitution.

(Petition, ECF No. 1, PageID 8).

The State of Ohio raises no affirmative defenses, but asserts the Twelfth District’s decision that there was sufficient evidence is entitled to deference under 28 U.S.C. § 2254(d)(1). Petitioner’s Traverse attempts to rebut that finding.

Analysis

An allegation that a verdict was entered upon insufficient evidence states a claim under the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Jackson v. Virginia, 443 U.S. 307 (1979); In re Winship, 397 U.S. 358 (1970); Johnson v. Coyle, 200 F.3d 987, 991 (6th Cir. 2000); Bagby v. Sowders, 894 F.2d 792, 794 (6th Cir. 1990)(en banc). In order for a conviction to be constitutionally sound, every element of the crime must be proved beyond a reasonable doubt. In re Winship, 397 U.S. at 364. [T]he relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt . . . . This familiar standard gives full play to the responsibility of the trier of fact fairly to resolve conflicts in the testimony, to weigh the evidence and to draw reasonable inferences from basic facts to ultimate facts.

Jackson v. Virginia, 443 U.S. at 319; Smith v. Nagy, 962 F.3d 192, 205 (6th Cir. 2020) (quoting Jackson). This standard “must be applied with explicit reference to the substantive elements of the criminal offense as defined by state law.” Id. (quoting Jackson, 443 U.S. at 324). This rule was recognized in Ohio law at State v. Jenks, 61 Ohio St. 3d 259 (1991). Of course, it is state law which determines the elements of offenses; but once the state has adopted the elements, it must then prove each of them beyond a reasonable doubt. In re Winship, supra. In cases such as Petitioner’s challenging the sufficiency of the evidence and filed after enactment of the Antiterrorism and Effective Death Penalty Act of 1996 (Pub. L. No 104-132, 110 Stat. 1214)(the “AEDPA”), two levels of deference to state decisions are required: In an appeal from a denial of habeas relief, in which a petitioner challenges the constitutional sufficiency of the evidence used to convict him, we are thus bound by two layers of deference to groups who might view facts differently than we would. First, as in all sufficiency-of-the-evidence challenges, we must determine whether, viewing the trial testimony and exhibits in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. See Jackson v. Virginia, 443 U.S. 307, 319, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979). In doing so, we do not reweigh the evidence, re- evaluate the credibility of witnesses, or substitute our judgment for that of the jury. See United States v. Hilliard, 11 F.3d 618, 620 (6th Cir. 1993). Thus, even though we might have not voted to convict a defendant had we participated in jury deliberations, we must uphold the jury verdict if any rational trier of fact could have found the defendant guilty after resolving all disputes in favor of the prosecution. Second, even were we to conclude that a rational trier of fact could not have found a petitioner guilty beyond a reasonable doubt, on habeas review, we must still defer to the state appellate court's sufficiency determination as long as it is not unreasonable. See 28 U.S.C. § 2254(d)(2).

Brown v. Konteh, 567 F.3d 191, 205 (6th Cir. 2009). In a sufficiency of the evidence habeas corpus case, deference should be given to the trier-of-fact's verdict under Jackson v. Virginia and then to the appellate court's consideration of that verdict, as commanded by AEDPA. Tucker v. Palmer, 541 F.3d 652 (6th Cir. 2008); accord Davis v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re WINSHIP
397 U.S. 358 (Supreme Court, 1970)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Brooks v. Tennessee
626 F.3d 878 (Sixth Circuit, 2010)
Carr X. Johnson v. Joseph H. Havener
534 F.2d 1232 (Sixth Circuit, 1976)
Davis v. Lafler
658 F.3d 525 (Sixth Circuit, 2011)
Cavazos v. Smith
132 S. Ct. 2 (Supreme Court, 2011)
United States v. Rockie Lane Hilliard
11 F.3d 618 (Sixth Circuit, 1994)
Michael Jeffrey Johnson v. Ralph Coyle, Warden
200 F.3d 987 (Sixth Circuit, 2000)
Coleman v. Johnson
132 S. Ct. 2060 (Supreme Court, 2012)
Parker v. Matthews
132 S. Ct. 2148 (Supreme Court, 2012)
Brown v. Konteh
567 F.3d 191 (Sixth Circuit, 2009)
Stewart v. Wolfenbarger
595 F.3d 647 (Sixth Circuit, 2010)
Tucker v. Palmer
541 F.3d 652 (Sixth Circuit, 2008)
State v. Jones
2013 Ohio 150 (Ohio Court of Appeals, 2013)
Nash v. Eberlin
258 F. App'x 761 (Sixth Circuit, 2007)
Keith Smith v. Noah Nagy
962 F.3d 192 (Sixth Circuit, 2020)
State v. Enoch
2020 Ohio 3406 (Ohio Court of Appeals, 2020)
Renico v. Lett
176 L. Ed. 2d 678 (Supreme Court, 2010)
State v. Grinstead
958 N.E.2d 177 (Ohio Court of Appeals, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Singh v. Warden, Noble Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/singh-v-warden-noble-correctional-institution-ohsd-2025.