Thomas v. Taylor

CourtDistrict Court, D. Delaware
DecidedDecember 12, 2024
Docket1:23-cv-01069
StatusUnknown

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

Bluebook
Thomas v. Taylor, (D. Del. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DAMIAN THOMAS, Petitioner,

v. Civil Action No. 23-1069-GBW BRIAN EMIG, Warden, and ATTORNEY GENERAL OF THE _ : STATE OF DELAWARE, : Respondents. :

MEMORANDUM ORDER

Pending before the Court is Petitioner’s Motion for Discovery (D.I. 16), the State’s Response in Opposition (D.I. 19), and Petitioner’s Reply to the State’s Response (D.J. 22). Petitioner seeks discovery regarding three Claims in his Petition: (1) Claim One, which asserts that his due process rights were violated when his convictions were obtained through the use of Monica Pruden’s perjured testimony; (2) Claim Two, which asserts that his due process rights were violated when the State committed prosecutorial misconduct relating to presenting the testimony of Monica Pruden; and (3) Claim Three, which asserts that his due process rights were violated when the State violated Brady v. Maryland, 373 U.S. 83 (1963)

by failing to turn over impeachment information establishing that Monica Pruden

was incarcerated at the time of the murder and, thus, she could not witnessed the incident. (D.I. 3) The Parties acknowledge that the Delaware state courts determined Claims One, Two, and Three are procedurally defaulted. (D.I. 3 at 27; D.I. 9 at 25-26) I. STANDARD OF REVIEW “A habeas petitioner, unlike the usual civil litigant in federal court, is not entitled to discovery as a matter of ordinary course.” Bracy v. Gramley, 520 U.S. 899, 904 (1997); Vasquez v. Glover, 2010 WL 2569715, at *1 (D.N.J. June 24, 2010). Rather, decisions on discovery requests rest in the sound discretion of the

court. See Levi v. Holt, 192 F. App’x 158, 162 (3d Cir. 2006). Rules 6 and 7 of the Rules Governing Section 2254 Cases in the United States District Courts provide further guidance for discovery issues in habeas proceedings. Pursuant to Rule 6(a), a court may authorize a party to conduct discovery under the Federal Rules of Criminal or Civil Procedure only if the court determines there is “good cause” for such discovery. See Rule 6(a), 28 U.S.C. foll. § 2254. Rule 6(b) states that a “party requesting discovery must provide reasons for the request [...] and must specify any requested documents.” Rule 6(b), 28 U.S.C. 28 U.S.C. foll. § 2254. Good cause exists where specific allegations before the court show reason to believe that the petitioner may, if the facts are fully developed, be able to demonstrate that he is

entitled to relief. See Harris v. Nelson, 394 U.S. 286, 300 (1969); Williams v. Beard, 637 F.3d 195, 209 (3d Cir. 2011) (“The burden rests upon the [movant] to demonstrate that the sought-after information is pertinent and that there is good cause for its production.”); Deputy v. Taylor, 19 F.3d 1485, 1493 (3d Cir. 1994) (a petitioner establishes “good cause” by “point[ing] to specific evidence that might be discovered that would support a constitutional claim”). When determining if “good cause” exists, the court should consider the “essential elements” of the petitioner’s underlying habeas claim. See Bracy, 520 U.S. at 904. Nevertheless, even in cases where “it would be an abuse of discretion not to permit any discovery,” “Rule 6(a) makes it clear that the scope and extent of such discovery is a matter confided to the discretion of the District Court.” Jd. at 909. In turn, Rule 7 states that a federal court may “direct the parties to expand the record by submitting additional materials relating the to the petition.” See Rule 7(a), 28 U.S.C. foll. § 2254. Although discovery in a habeas proceeding may not be used to embark on a fishing expedition intended to develop claims for which there is no factual basis,’ a petitioner need not demonstrate that additional discovery will definitively lead to relief. Rather, a petitioner “need only show good cause that the discovery will lead to relevant evidence regarding his petition.” Williams v. Wetzel, 2021 WL 1224130, at *2 (E.D. Pa. Mar. 31, 2021).

‘Williams, 637 F.3d at 211.

Since AEDPA requires a district court to base its resolution of a habeas claim solely on the state-court record, discovery is not available for claims that were not presented to the state courts in compliance with state procedural rules, unless the petitioner shows that factual development in federal court is appropriate under 28 U.S.C. § 2254(e)(2). See Shinn v. Ramirez, 596 U.S. 366, 375-76, 378-79 (2022). Section 2254(e)(2) bars evidentiary development when the petitioner has failed to develop the factual basis of a claim in State court proceedings unless the petitioner shows that: (A) the claim relies on —

(i) a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable; or (ii) a factual predicate that could not have been previously discovered through the exercise of due diligence; and (B) the facts underlying the claim would be sufficient to establish by clear and convincing evidence that but for constitutional error, no reasonable factfinder would have found the applicant guilty of the underlying offense. 28 U.S.C. § 2254(e)(2). Additionally, in Shoop v. Twyford, 596 U.S. 811 (2022), the Supreme Court emphasized that, “if §2254(e)(2) applies and the prisoner cannot

meet the statute’s standards for admitting new merits evidence, it serves no purpose to develop such evidence just to assess cause and prejudice. ” Jd. at 823.

Notably, “[e}ven if ali of these requirements are satisfied, a federal habeas

court still is not required to hold a hearing or take any evidence. Like the decision

to grant habeas relief itself, the decision to permit new evidence must be informed by principles of comity and finality that govern every federal habeas case.” Shinn, 596 US. at 380-81. Il. DISCUSSION Petitioner’s Motion asks for the following discovery: 1. All documents, emails, texts, records, and notes in the custody or control of the Delaware Attorney General’s Office that were obtained and reviewed pretrial regarding Ms. Pruden’s custody status and her ability to leave DOC custody on April 14, 2015; 2. All documents, emails, texts, records, and notes in the custody or control of the Delaware Attorney General’s Office that were obtained and reviewed during Mr. Thomas’ trial relating to Ms. Pruden’s custody status and her ability to leave DOC custody on April 14, 2015; 3. All documents, emails, texts, records, and notes in the custody or control of the Delaware Attorney General’s Office that were obtained after [Petitioner’s] trial regarding Ms. Pruden’s custody status and her ability to leave DOC custody on April 14, 2015; 4. All records, other than correspondence and communications placed on the docket, in the custody or control of the Delaware Attorney General’s Office, including, but not limited to letters, emails, texts, retained voice mails and notes of phone calls, reflecting and/or discussing communications regarding Ms. Pruden’s custody status and her ability to leave DOC

custody on April 14, 2015.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Harris v. Nelson
394 U.S. 286 (Supreme Court, 1969)
Bracy v. Gramley
520 U.S. 899 (Supreme Court, 1997)
Williams v. Beard
637 F.3d 195 (Third Circuit, 2011)
Levi v. Holt
192 F. App'x 158 (Third Circuit, 2006)
Shinn v. Martinez Ramirez
596 U.S. 366 (Supreme Court, 2022)
Shoop v. Twyford
596 U.S. 811 (Supreme Court, 2022)

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Thomas v. Taylor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-v-taylor-ded-2024.