Spates v. Buckner

CourtDistrict Court, E.D. Missouri
DecidedMarch 28, 2025
Docket4:22-cv-00011
StatusUnknown

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

Bluebook
Spates v. Buckner, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

CHRISTOPHER SPATES, ) ) Petitioner, ) )

v. ) ) MICHELLE BUCKNER, et al., ) Case No. 4:22-cv-00011-MTS ) Respondents. )

MEMORANDUM AND ORDER

This matter is before the Court on Petitioner Christopher Spates’s Petition under 28 U.S.C. § 2254 for writ of habeas corpus. For the following reasons, Petitioner’s § 2254 Petition is denied. I. Factual and Procedural History

Angela Young was murdered on August 23, 2011. At that time, Leon Moss had pending charges for domestic assault and armed criminal action for acts he committed against Young. During that summer, Moss met with Petitioner and other associates to devise a plan to murder Young. Moss told his associates that he would pay $10,000 for Young to be killed to prevent her from testifying against him in the domestic assault case because he was facing a significant amount of time and did not want to go back to prison. Donald White told Moss he could get it done. At one of the meetings, Raymond Jones was introduced to Petitioner, and Jones agreed to drive Petitioner to murder Young. During the evening of August 23, 2011, Young pulled her car into a White Castle parking lot in north St. Louis. Id. Nearby video surveillance recorded a white truck following her car. At around 11:30 p.m., Petitioner got out of the white truck and started walking towards Young’s car. Id. When Petitioner reached the driver’s side window of Young’s car, he pulled out a gun and shot through it repeatedly. Id. He then ran into a nearby alley and eventually drove off in the white truck. Id. Young died at the scene, having been shot numerous times in her head and neck. Moss was

contacted by the police because he was listed as Young’s emergency contact. Moss said he did not want the police to come to his home, but he agreed to go to police headquarters to speak with them. Moss never showed up. However, he did return a phone call from the police, telling them he would not be coming in because his attorney told him not to go. Police began investigating Moss for his role in the murder. The Police later found the white pickup truck involved in the murder outside of a property owned by Moss. The police obtained a search warrant for the truck and found fingerprints on the exterior passenger side of the truck that matched Petitioner. Petitioner, Moss, and White were tried by jury in a joint criminal trial. Petitioner was found guilty of first-degree murder and armed criminal action. He was sentenced to life without

the possibility of parole for the murder, and 30 years of imprisonment for armed criminal action. On August 2, 2016, the court of appeals affirmed the trial court on direct appeal. State v. Spates, 494 S.W.3d 646 (Mo. App. E.D., 2016). Petitioner raised points related to the denial of severance, denial of access to federal document discovery, the admissibility of phone records, and the testimony of a state witness. Doc. [4-7]. Petitioner then filed a motion under Supreme Court of Missouri Rule 29.15 for post-conviction relief. After an evidentiary hearing, the state motion court entered a judgment denying post-conviction relief on September 30, 2019. Petitioner appealed and the court of appeals affirmed the denial of Petitioner’s motion for post- conviction relief. Spates v. State, 618 S.W.3d 717 (Mo. App. E.D., 2021). On January 4, 2022, Petitioner filed this action for habeas relief. Doc. [1]. II. Legal Standard The proper standard of review for habeas relief is dependent upon whether the ground for relief was adjudicated on the merits in state court proceedings or is procedurally barred. A. Claims Reviewed on the Merits

When a claim has been adjudicated on the merits in state court proceedings, habeas relief is permissible under the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), though such relief is “limited and deferential.” Lomholt v. Iowa, 327 F.3d 748, 751 (8th Cir. 2003). Under AEDPA, § 2254(d), habeas relief is only permissible if the state court’s determination: (1) Resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) Resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding. § 2254(d)(1)–(2). A state court’s decision is “contrary to” clearly established Federal law if “it applies a rule that contradicts the governing law set forth in [the Supreme Court’s] cases, or if it confronts a set of facts that is materially indistinguishable from a decision of the [Supreme Court] but reaches a different result.” Brown v. Payton, 544 U.S. 133, 141 (2005). A decision involves an “unreasonable application” of clearly established law if “ the state court applies [the Supreme Court’s] precedents to the facts in an objectively unreasonable manner,” id. at 141, or “if the state court unreasonably extends a legal principle from [Supreme Court] precedent to a new context where it should not apply or unreasonably refuses to extend that principle to a new context where it should apply.” Williams v. Taylor, 529 U.S. 362, 407 (2000). When reviewing whether a state court decision involves an “unreasonable determination of facts,” state court findings of “basic, primary, or historical facts” are presumed correct unless the petitioner rebuts the presumption with clear and convincing evidence. Collier v. Norris, 485 F.3d 415, 423 (8th Cir. 2007) (citations omitted); 28 U.S.C. § 2254(e)(1).

B. Ineffective Assistance of Counsel Claims To prevail on his ineffective assistance of counsel claims, Petitioner must show that his attorney’s performance fell below an objective standard of reasonableness and that he was prejudiced thereby. Strickland v. Washington, 466 U.S. 668, 688 (1984). With respect to the first Strickland prong, there is a strong presumption that counsel’s conduct falls within the wide range of professionally reasonable assistance. Id. at 689. To establish the “prejudice” prong, the movant must show “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 694. “Merely showing a conceivable effect is not enough; a reasonable probability is one sufficient to undermine confidence in the outcome.” Paulson v. Newton Corr. Facility, 773 F.3d 901, 904 (8th Cir. 2014)

(citation omitted). “Taken together, AEDPA and Strickland establish a ‘doubly deferential standard’ of review.” Williams v. Roper, 695 F.3d 825, 831 (8th Cir. 2012) (quoting Cullen v. Pinholster, 563 U.S. 170, 202 (2011)). First, under Strickland, the state court must make a predictive judgment about the effect of the alleged deficiencies of counsel on the outcome of the trial, focusing on whether it is “reasonably likely” that the result would have been different absent the errors. Strickland, 466 U.S. at 696. To satisfy Strickland, the likelihood of a different result must be “substantial, not just conceivable.” Harrington v. Richter, 562 U.S. 86, 112 (2011). Under AEDPA, federal courts must then give substantial deference to the state court’s predictive judgment.

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United States v. Frady
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Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Estelle v. McGuire
502 U.S. 62 (Supreme Court, 1991)
Brown v. Payton
544 U.S. 133 (Supreme Court, 2005)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
Thomas L. Fitzgerald v. Bill Armontrout
963 F.2d 1062 (Eighth Circuit, 1992)
Harrison Jolly v. James A. Gammon, Supt.
28 F.3d 51 (Eighth Circuit, 1994)
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Spates v. Buckner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spates-v-buckner-moed-2025.