Sliney v. Secretary, DOC

CourtDistrict Court, M.D. Florida
DecidedMarch 18, 2024
Docket2:06-cv-00670
StatusUnknown

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Bluebook
Sliney v. Secretary, DOC, (M.D. Fla. 2024).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION

JACK RILEA SLINEY,

Petitioner,

v. Case No: 2:06-cv-670-JES-NPM

SECRETARY, DEPARTMENT OF CORRECTIONS,

Respondent.

OPINION AND ORDER This matter comes before the Court on Petitioner Jack Rilea Sliney’s Motion for Relief from Judgment Pursuant to Rule 60 of the Federal Rules of Civil Procedure (Doc. 42) and Request for Evidentiary Hearing (Doc. 43), the Secretary of the Florida Department of Corrections’ Response (Doc. 48), and Sliney’s Reply (Doc. 51). In 1993, a Florida court convicted Sliney of first-degree murder and sentenced him to death. The conviction withstood direct appeal and state collateral challenges, and Sliney sought federal habeas corpus relief in this Court. He asserted six grounds for relief, but only one is relevant here. Sliney claimed his trial attorney, Kevin Shirley, rendered ineffective assistance of counsel due to an actual conflict of interest that adversely affected his performance. The ground was based on Shirley’s relationship with Detective Lloyd Hamilton Sisk. In Ground 6 of Sliney’s initial federal habeas petition, he alleged that Sisk was charged with crimes against a minor years earlier. The charges were dismissed after a mistrial, but Sisk

was fired from his job with the Charlotte County Sheriff’s Office. Shirley represented Sisk in his appeal to the Career Services Review Board, and in a wrongful termination suit. Shirley also represented Sisk in his divorce. Both cases concluded before Sliney hired Shirley. However, Shirley was representing Sisk’s son in a divorce case while representing Sliney. Shirley did not tell Sliney about his relationship with the Sisk family, even though Sisk participated in the investigation of Sliney and testified in a suppression hearing and as a rebuttal witness at trial. The Court1 found the Florida Supreme Court applied the correct legal standard, then explained why the rejection of Sliney’s claim

was a reasonable application of that standard:

Here, as the Florida courts recognized, Petitioner has alleged a potential conflict of interest because counsel was put in a position where he had to cross-examine his former client. Lightbourne, 829 F.2d at 1023 (citation omitted)(noting potential conflict when attorney had to cross-examine his former client). The record evidence shows, however, that counsel’s former client, Detective Sisk, was not the lead detective in the case against Sliney. Detective Sisk’s activity in the case consisted of assisting with Petitioner’s arrest and being present

1 United States District Judge Charlene Edwards Honeywell decided Sliney’s habeas petition. The case was reassigned to the undersigned judge on October 30, 2018. for the initial part of Sliney’s confession. Exh. A11 at 1175. Sisk’s participation at trial was even more limited as he was called only as a rebuttal witness to testify about Sliney’s appearance at the time of his arrest and whether he appeared intoxicated at that time. Id. at 1169-1175. Sisk testified that Sliney did not appear intoxicated during the arrest and was not physically ill while at the police station. On cross- examination, counsel elicited testimony from Sisk in which Sisk admitted that he was not in the interview room during Petitioner’s taped statement and was not present with Sliney at all times during the morning of his arrest. Exh. A11 at 1174-1175. Thus, Sisk was not a critical witness to the State’s case and merely provided cumulative testimony to that offered by Detective Twardzick regarding Sliney’s appearance.

Indeed, counsel had previously represented Sisk in civil matters: first, a lawsuit concerning reinstatement of his employment, and then a divorce proceeding. The Court presumes that Detective Sisk shared confidential information with his counsel during these proceedings related to the subject of his representation. However, Sisk’s civil cases had no relation whatsoever to Petitioner’s trial. Any information counsel learned about Sisk before representing Sliney was entirely irrelevant to Sliney’s case. Moreover, as the State court found, Petitioner failed to present any evidence to show that the cases were substantially and particularly related, because the only testimony collateral counsel elicited during the hearing was Petitioner Sliney’s testimony. While Petitioner now submits that he is unsure what “expert” testimony he should have presented to the postconviction court, the Court’s review of the record shows that the post- conviction court merely pointed out that Petitioner failed to present testimony from Attorney Shirley on the matter. Significantly, collateral counsel never elicited testimony from either Attorney Shirley or Detective Sisk during the evidentiary hearing about the scope and nature of counsel’s prior representation of Sisk. Thus, the Court finds that counsel’s earlier representations of Sisk were not substantially and particularly related; and, as such, counsel was not operating under an actual conflict of interest. Assuming only arguendo that an actual conflict of interest existed in this case, Petitioner was also required to establish that the conflict caused an adverse effect on his representation. In denying Petitioner relief on this claim, the Florida courts focused on Petitioner’s failure to establish an adverse effect. “Adverse effect” has three necessary elements that a petitioner must establish:

First, he must point to ‘some plausible alternative defense strategy or tactic [that] might have been pursued. . . . . Second, he must demonstrate that the alternative strategy or tactic was reasonable under the facts. Because prejudice is presumed, . . . . the petitioner ‘need not show that the defense would necessarily have been successful if [the alternative strategy or tactic] had been used, ‘rather he only need prove that the alternative ‘possessed sufficient substance to be a viable alternative.’ . . . . Finally, he must show some link between the actual conflict and the decision to forego the alternative strategy of defense. In other words, ‘he must establish that the alternative defense was inherently in conflict with or not undertaken due to the attorney’s other loyalties or interests.’ . . . . It bears repeating, however, that ‘[p]rejudice is presumed only if the defendant demonstrates that . . . ‘an actual conflict of interest’ adversely affected his lawyer’s performance.’

Freund, at 861.

Petitioner argues that Shirley did not cross-examine Sisk on matters Petitioner brought to his attention during trial because he was operating under a conflict of interest. The State courts determined that Petitioner failed to show an adverse effect because Petitioner did not testify to the substance of the matters he requested counsel to raise during the cross-examination of Sisk, which he alleges counsel failed to raise. Instead, the Florida Supreme Court noted that Petitioner acknowledged that counsel brought out all of the allegations he wanted, including allegations that he was intoxicated at the time of his confession. The record evidence does not show that counsel was impaired in his ability to cross- examine Sisk because of his prior representation of the rebuttal witness. The Florida Supreme Court’s decision was not contrary to, or an unreasonable application of, this clearly established federal law.

The Florida Supreme Court’s decision did not involve an unreasonable determination of the facts. Therefore, Petitioner is denied relief on Ground Six.

(Doc. #25 at 53-58.) Sliney now seeks relief from judgment under

Related

Williams v. Chatman
510 F.3d 1290 (Eleventh Circuit, 2007)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
Gonzalez v. Crosby
545 U.S. 524 (Supreme Court, 2005)

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Sliney v. Secretary, DOC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sliney-v-secretary-doc-flmd-2024.