Smith v. Eppinger

CourtDistrict Court, N.D. Ohio
DecidedMay 20, 2025
Docket5:20-cv-00438
StatusUnknown

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

Bluebook
Smith v. Eppinger, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

DAVID SMITH, ) Case No. 5:20-cv-438 ) Petitioner, ) Judge J. Philip Calabrese ) v. ) Magistrate Judge Darrell A. Clay ) CYNTHIA DAVIS, ) ) Respondent. ) )

OPINION AND ORDER The Sixth Circuit reversed the denial of a writ of habeas corpus and remanded “with instructions that the district court issue Smith a writ of habeas corpus unless the State proceeds, within 180 days, to prosecute Smith in a new trial without utilizing Tolliver’s identification of Smith, which shall be suppressed and excluded from evidence.” (ECF No. 33, PageID #3060.) After a retrial in State court, Petitioner filed a motion to enforce the conditional writ, arguing that the State failed to follow the mandate issued pursuant to the Sixth Circuit’s ruling. Following briefing and oral argument, the Court granted Petitioner’s motion to enforce. (ECF No. 52.) After that ruling, the Court administratively stayed its ruling over Petitioner’s objection until noon on July 28, 2025 to allow a decision on a stay of its ruling pending appeal in the normal course. Respondent then moved for a stay pending appeal. ANALYSIS Although the parties have each appealed, the Court retains jurisdiction to enter a stay or set bail. See Fed. R. App. P. 8(a)(1); Fed. R. App. P. 23(c). While there is a presumption that a successful habeas petitioner should be released from custody pending the State’s appeal of a grant of habeas relief, this presumption can be overcome if the judge rendering the decision, or an appellate court or judge, orders

otherwise. Hilton v. Braunskill, 481 U.S. 770, 774 (1987); Fed. R. App. P. Rule 23(c). The standards governing stays of civil judgements apply to the release of habeas petitioners pending appeal. Hilton, 481 U.S. at 776. I. Traditional Stay Factors The traditional factors for the issuance of a stay are: (1) whether the applicant has made a strong showing that he is likely to succeed on the merits; (2) whether the applicant will be irreparably injured absent a stay; (3) whether the issuance of the

stay will substantially injure the other parties interested in the proceeding; and (4) where the public interest lies. Id.; Workman v. Tate, 958 F.2d 164, 166 (6th Cir. 1992). I.A. Likelihood of Success Respondent argues that the Court’s decision was “without precedent” and, therefore, claims a likelihood of succeed on the merits on appeal. (ECF No. 56, PageID #3946.) To make this argument, Respondent cites three cases: (1) Pitchess

v. Davis, 421 U.S. 482 (1975) (per curiam); (2) Eddleman v. McKee, 586 F.3d 409 (6th Cir. 2009); and (3) Gillispie v. Warden, London Corr. Inst., 771 F.3d 323 (6th Cir. 2014). When deciding that it had jurisdiction over Petitioner’s motion to enforce, the Court gave consideration to each case and explained why the reasoning of each did not help Respondent. (See ECF No. 52, PageID #3897–3900.) Moreover, the Court made its jurisdictional determination by reference to Circuit precedent in D’Ambrosio v. Bagley, 656 F.3d 379 (6th Cir. 2011), and the discussion between Justice Scalia and Justice Thomas in Jennings v. Stephens, 574 U.S. 271 (2015). (See ECF No. 52, PageID #3891 & #3912–14.) Based on the limited discussion in Respondent’s motion

for a stay, and the analysis of the jurisdictional question following briefing and oral argument in the Court’s Opinion and Order dated May 12, 2025 (ECF No. 52), the Court cannot say that Respondent carried her burden of showing a likelihood of success on the merits on appeal, even recognizing the difficulty of making the same argument before a tribunal that previously found it wanting. For her argument, Respondent also relies on Petitioner’s emergency motions

on the eve of the retrial of Petitioner David Smith at the Sixth Circuit and in the district court seeking clarification (prohibition, really) that the conditional writ did not allow the identification ultimately used at the retrial. (ECF No. 56, PageID #3946.) As the Court previously explained, this position reads too much into the emergency posture of Petitioner’s requests. Nor does it properly understand the role of a federal court exercising habeas jurisdiction, which does not extend to general supervision of proceedings in State court.

Beyond these arguments, Respondent says nothing about the use of Tolliver’s identification of Mr. Smith at his retrial. For all these reasons, this factor cuts against a stay. I.B. Irreparable Harm to the State The Court recognizes that the State has a “strong interest in enforcing its criminal judgments in defending the integrity of its judicial system.” Miller v. Stovall, 641 F. Supp. 2d 657, 670 (E.D. Mich. 2009). In recognition of that interest, the Court issued a conditional writ, to afford the State the opportunity to vindicate its interests. As explained in its Opinion and Order dated May 12, 2025 (ECF No. 52, PageID #3905–08), the conviction at Mr. Smith’s retrial in the State trial court suffers

from the same constitutional violation that the Sixth Circuit found in his first. Although this factor favors a stay pending appeal, the fact that the State had the opportunity to protect its interests and failed to do so diminishes the force of this consideration somewhat on this record. I.C. Substantial Injury to Other Interested Parties Here, the Court recognizes the interests of both the victim, Quortney Tolliver, and Petitioner David Smith. In Dovala v. Baldauf, No. 1:16-cv511, 2021 WL 1699917,

at *8 (N.D. Ohio Apr. 29, 2021) (collecting cases), the court considered the victims interested parties after they presented statements through their representatives. That did not happen here. Still, Tolliver has an interest in this matter even if she has now moved out of State, did not attend the federal proceedings, and provided no statement to the Court. Petitioner’s continued incarceration in violation of the writ issued pursuant to

the Sixth Circuit’s mandate constitutes irreparable harm. Even taking account of Tolliver’s interests, Mr. Smith’s liberty interest carries the day under this stay factor. I.D. Public Interest Finally, the Court considers “where the public interest lies.” Hilton, 481 U.S. at 776. In many respects, the competing values and interests that inhere in the writ express the public interest. Principles of comity, federalism, and finality limit the reach of the writ, which nonetheless guards against unconstitutional convictions. In those limited and rare circumstances where a writ may issue, its equitable nature seeks to vindicate the ends it serves. Here, the Sixth Circuit ruled that the State may hold Mr. Smith only after a trial that did not use Tolliver’s identification. That did

not happen. On the totality of the facts and circumstances presented, the public interest favors giving effect to the writ pending appeal. Indeed, a habeas petitioner enjoys a presumption of release following the issuance of a writ. Fed. R. App. P. 23(c); Hilton, 481 U.S. at 774.

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

Related

Pitchess v. Davis
421 U.S. 482 (Supreme Court, 1975)
Hilton v. Braunskill
481 U.S. 770 (Supreme Court, 1987)
Daniel Workman v. Arthur Tate, (Workman Ii)
958 F.2d 164 (Sixth Circuit, 1992)
D'AMBROSIO v. Bagley
656 F.3d 379 (Sixth Circuit, 2011)
Eddleman v. McKee
586 F.3d 409 (Sixth Circuit, 2009)
Miller v. Stovall
641 F. Supp. 2d 657 (E.D. Michigan, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
Smith v. Eppinger, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-eppinger-ohnd-2025.