Sjoberg v. Henley

CourtDistrict Court, D. Nevada
DecidedFebruary 10, 2025
Docket3:20-cv-00322
StatusUnknown

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

Bluebook
Sjoberg v. Henley, (D. Nev. 2025).

Opinion

2 UNITED STATES DISTRICT COURT

3 DISTRICT OF NEVADA

4 THOMAS JUSTIN SJOBERG, Case No. 3:20-cv-00322-ART-CLB

5 Petitioner, ORDER v. 6 JOHN HENLEY,1 7 Respondents. 8 9 Petitioner Thomas Justin Sjoberg (“Petitioner” or “Sjoberg”), who entered 10 an Alford2 plea to lewdness with a child under the age of 14 years and was 11 sentenced to ten years to life in prison, filed a petition for writ of habeas corpus 12 under 28 U.S.C. § 2254. (See ECF Nos. 1; 17-7.) This matter is before this court 13 for adjudication of the merits of the remaining ground3 in Sjoberg’s petition, 14 which alleges that his counsel was ineffective in advising him to enter an Alford 15 plea rather than filing a motion to suppress his law enforcement interview. (ECF 16 No. 1 at 25.) Given that Sjoberg was subjected to a custodial interrogation without 17 a valid waiver of his Miranda rights, this court grants the petition. 18 I. BACKGROUND 19 The State filed a criminal complaint in state justice court charging Sjoberg 20 with various counts regarding his alleged conduct towards his stepdaughter, 21 A.L.4: sexual assault on a child under the age of 16 years; lewdness with a child

22 1 The state corrections department’s inmate locator page states that Sjoberg is incarcerated at Northern Nevada Correctional Center. John Henley is the current warden for that facility. At the 23 end of this order, this court directs the clerk to substitute John Henley as a respondent for Respondent Isidro Baca. See Fed. R. Civ. P. 25(d). 24 2 See North Carolina v. Alford, 400 U.S. 25, 37–38 (1970) (holding that a defendant can enter a valid guilty plea while still maintaining his innocence where there is a factual basis for the plea 25 and the plea is voluntary, knowing, and intelligent). 3 This court previously dismissed ground 1 based on Tollett v. Henderson, 411 U.S. 258 (1973). 26 (See ECF No. 28 at 3–4.) 4 The Local Rules of Practice state that “[p]arties must refrain from including—or must partially 27 redact, where inclusion is necessary—[certain] personal-data identifiers from all documents filed with the court, including exhibits, whether filed electronically or in paper, unless the court orders 28 1 under the age of 14 years; abuse, neglect, and/or endangerment of a child; 2 battery with intent to commit sexual assault; and open or gross lewdness. (ECF 3 No. 16-1 at 11–13.) Sjoberg conditionally waived his preliminary hearing “for the 4 purpose of obtaining a competency evaluation.” (Id. at 18.) Sjoberg’s case was 5 transferred to the state district court. (Id. at 2.) 6 Following a request by Sjoberg’s counsel who represented him through his 7 arraignment (hereinafter “arraignment counsel”), the state district court issued 8 an order for competency, ordering Sjoberg to be evaluated at Lake’s Crossing to 9 determine his “ability to assist his counsel in presenting a defense with a 10 reasonable degree of rational understanding.” (ECF No. 16-5 at 3.) Sjoberg’s 11 competency evaluation was conducted and indicated that Sjoberg was competent, 12 so the state district court remanded the case to the state justice court for a 13 preliminary hearing. (ECF No. 16-7 at 4–7.) Sjoberg waived that hearing, and his 14 case was transferred back to the state district court. (ECF No. 16-9 at 27–28.) A 15 week later, the State filed a new information amending Sjoberg’s charges to a 16 single count of lewdness with a child under the age of 14 years. (ECF No. 16-10.) 17 Sjoberg entered an Alford plea to the single charge in return for the State agreeing 18 to dismiss the other original charges. (ECF Nos. 16-12 at 10; 16-13 at 2.) 19 Prior to sentencing, Sjoberg received new counsel (hereinafter “post- 20 arraignment counsel”) and moved for a new trial, which the state district court 21 construed as moving to withdraw his plea. (ECF Nos. 16-16; 16-18 at 4.) After an 22 evidentiary hearing, the state district court denied the motion. (ECF Nos. 17-1; 23 17-2.) Sjoberg was sentenced to ten years to life in prison. (ECF No. 17-7.) Sjoberg 24 appealed, and the Nevada Court of Appeals affirmed. (ECF No. 18-5.) 25 Sjoberg filed a post-conviction habeas corpus petition in state court. (ECF 26 No. 18-7.) An evidentiary hearing was held on Sjoberg’s petition, and Sjoberg’s 27 otherwise.” LR IA 6-1(a). This includes the names of minor children, so this court only uses the 28 victim’s initials. 1 arraignment counsel, among others, testified. (ECF No. 21-1.) The state district 2 court denied the petition. (ECF No. 22-1.) Sjoberg appealed, and the Nevada Court 3 of Appeals affirmed. (ECF No. 23-4.) Sjoberg then filed the instant federal habeas 4 corpus petition. (ECF No. 1.) 5 II. GOVERNING STANDARDS OF REVIEW 6 A. Antiterrorism and Effective Death Penalty Act (“AEDPA”) 7 28 U.S.C. § 2254(d) sets forth the standard of review generally applicable 8 in habeas corpus cases under AEDPA:

9 An application for a writ of habeas corpus on behalf of a person in 10 custody pursuant to the judgment of a State court shall not be granted with respect to any claim that was adjudicated on the merits 11 in State court proceedings unless the adjudication of the claim –

12 (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as 13 determined by the Supreme Court of the United States; or 14 (2) resulted in a decision that was based on an unreasonable 15 determination of the facts in light of the evidence presented in the State court proceeding. 16

17 A state court decision is contrary to clearly established Supreme Court precedent, 18 within the meaning of 28 U.S.C. § 2254, when “the state court applies a rule that 19 contradicts the governing law set forth in [the Supreme Court’s] cases” or “the 20 state court confronts a set of facts that are materially indistinguishable from a 21 decision of [the Supreme] Court.” Lockyer v. Andrade, 538 U.S. 63, 73 (2003) 22 (quoting Williams v. Taylor, 529 U.S. 362, 405–06 (2000), and citing Bell v. Cone, 23 535 U.S. 685, 694 (2002)). A state court decision is an unreasonable application 24 of clearly established Supreme Court precedent within the meaning of 28 U.S.C. 25 § 2254(d) when “the state court identifies the correct governing legal principle 26 from [the Supreme] Court’s decisions but unreasonably applies that principle to 27 the facts of the prisoner’s case.” Id. at 75 (quoting Williams, 529 U.S. at 413). 28 1 B. Standard for effective-assistance-of-counsel claims 2 In Strickland v.

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