Tucker v. Warden Belmont Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedApril 30, 2021
Docket1:20-cv-00628
StatusUnknown

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

Bluebook
Tucker v. Warden Belmont Correctional Institution, (S.D. Ohio 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI

WILLIAM TUCKER,

Petitioner, : Case No. 1:20-cv-628

- vs - District Judge Michael R. Barrett Magistrate Judge Michael R. Merz

WARDEN, Belmont Correctional Institution,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus case, brought pro se by Petitioner William Tucker pursuant to 28 U.S.C. § 2254, is before the Court for decision on the merits. Relevant filings are the Petition (ECF No. 1), the State Court Record (ECF No. 6), the Return of Writ (ECF No. 7), and Petitioner’s Reply (ECF No. 15). On April 28, 2021, the Court received and filed a request from Petitioner for a copy of his Reply as filed (ECF No. 18). That request is GRANTED and the Clerk shall forthwith furnish Plaintiff, without fee, with a copy of his Reply showing the CM/ECF header which is necessary for compliance with the Court’s record citation rule. The same document relates Petitioner’s belief that the State had fifteen days in which to file a response to his Reply. However, no rule or practice of this Court anticipates such a filing and the State has neither sought nor received leave to file such a response. The Magistrate Judge reference in the case was recently transferred to the undersigned to help balance the Magistrate Judge workload in the District (ECF No. 16).

Litigation History

In January of 2017, the Butler County Grand Jury indicted Tucker on two counts of aggravated arson in violation with Ohio Revised Code § 2909.02(A)(1), two counts of aggravated arson in violation with Ohio Revised Code § 2909.02(A)(2), and two counts of felony murder in violation with Ohio Revised Code § 2903.02(B). (Indictment, State Court Record, ECF No. 6, Exhibit 1). Tucker was indicted along with his uncle Lester Parker. The State’s theory was that Parker, intending to collect insurance proceeds, hired Tucker to burn his residence. A firefighter, Patrick Wolterman, was killed while fighting the fire. A jury found Tucker guilty of two counts of aggravated arson and one count of murder. After merging counts under Ohio Revised Code § 2941.25, the trial court sentenced Tucker to fifteen years to life imprisonment. Id. Ex. 5. Represented by new counsel, Tucker appealed to the Ohio Twelfth District Court of Appeals which affirmed the conviction. State v. Tucker, 2019-Ohio-911 (Ohio App. 12th Dist. Mar. 18, 2019), appellate review declined, 157 Ohio St. 3d 1484 (2019). Tucker filed his Petition for Writ of Habeas Corpus in this Court on August 6, 2020, the date he deposited it in the prison mail system. He pleads the following grounds for relief:

Ground One: Evidence was insufficient to support convictions and the verdict was against the manifest weight of the evidence.

Ground Two: Trial court erred to the prejudice of Tucker where it failed to grant his motion for relief from prejudicial joinder.

Ground Three: The State of Ohio engaged in prosecutorial misconduct at trial prejudicing the jury so that they clearly lost their way in convicting Tucker and causing a manifest injustice, due to being deprived of fair trial.

(Petition, ECF No. 1, PAGEID 5, 9, 13).

Ground One: Insufficient Evidence; Verdict Against the Manifest Weight of the Evidence

In his First Ground for Relief, Tucker asserts his conviction is supported by constitutionally insufficient evidence and is against the manifest weight of the evidence. These two claims are frequently pleaded together as Tucker did in his First Assignment of Error on direct appeal. Federal habeas corpus is available only to correct federal constitutional violations. 28 U.S.C. § 2254(a); Wilson v. Corcoran, 562 U.S. 1 (2010); Lewis v. Jeffers, 497 U.S. 764, 780 (1990); Smith v. Phillips, 455 U.S. 209 (1982), Barclay v. Florida, 463 U.S. 939 (1983). "[I]t is not the province of a federal habeas court to reexamine state court determinations on state law questions. In conducting habeas review, a federal court is limited to deciding whether a conviction violated the Constitution, laws, or treaties of the United States." Estelle v. McGuire, 502 U.S. 62, 67-68 (1991); see also Elmendorf v. Taylor, 23 U.S. (10 Wheat.) 152, 160 (1825)(Marshall C. J.); Bickham v. Winn, 888 F.3d 248 (6th Cir. Apr. 23, 2018)(Thapar, J. concurring). As Respondent asserts, a weight of the evidence claim is not a federal constitutional claim. Johnson v. Havener, 534 F.2d 1232 (6th Cir. 1986). However, an allegation that a verdict was entered upon insufficient evidence does state a claim under the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Jackson v. Virginia, 443 U.S. 307 (1979); In re Winship, 397 U.S. 358 (1970); Johnson v. Coyle, 200 F.3d 987, 991 (6th Cir. 2000);

Bagby v. Sowders, 894 F.2d 792, 794 (6th Cir. 1990)(en banc). In order for a conviction to be constitutionally sound, every element of the crime must be proved beyond a reasonable doubt. In re Winship, 397 U.S. at 364. [T]he relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt . . . . This familiar standard gives full play to the responsibility of the trier of fact fairly to resolve conflicts in the testimony, to weigh the evidence and to draw reasonable inferences from basic facts to ultimate facts.

Jackson v. Virginia, 443 U.S. at 319; Smith v. Nagy, 962 F.3d 192, 205 (6th Cir. 2020) (quoting Jackson). When an appellant combines these two claims in one assignment of error, an Ohio court of appeals will usually decide them together, as the Twelfth District did here, writing:

[*P6] THE EVIDENCE WAS INSUFFICIENT TO SUPPORT APPELLANT'S CONVICTIONS AND THE VERDICT WAS AGAINST THE MANIFEST WEIGHT OF THE EVIDENCE.

[*P7] Tucker argues that the state's evidence was legally insufficient to convict him of the aggravated arson counts as the evidence against him was entirely circumstantial. Tucker further argues that his convictions were against the weight of the evidence.

[*P8] The concept of legal sufficiency of the evidence refers to whether the conviction can be supported as a matter of law. State v. Everitt, 12th Dist. Warren No. CA2002-07-070, 2003-Ohio-2554, ¶ 10. In reviewing the sufficiency of the evidence, an appellate court must examine the evidence admitted at trial to determine whether such evidence, if believed, would convince the average mind of the defendant's guilt beyond a reasonable doubt. State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (1991), paragraph two of the syllabus. The relevant inquiry is whether, after reviewing the evidence in a light most favorable to the prosecution, any rational trier of fact would have found all the essential elements of the crime proven beyond a reasonable doubt. Id.

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Donnelly v. DeChristoforo
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Jackson v. Virginia
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Smith v. Phillips
455 U.S. 209 (Supreme Court, 1982)
Barclay v. Florida
463 U.S. 939 (Supreme Court, 1983)
United States v. Lane
474 U.S. 438 (Supreme Court, 1986)
Darden v. Wainwright
477 U.S. 168 (Supreme Court, 1986)
Lewis v. Jeffers
497 U.S. 764 (Supreme Court, 1990)
Estelle v. McGuire
502 U.S. 62 (Supreme Court, 1991)
Zafiro v. United States
506 U.S. 534 (Supreme Court, 1993)
Bell v. Cone
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Brown v. Payton
544 U.S. 133 (Supreme Court, 2005)
Williams v. Taylor
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United States v. Wettstain
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Wilson v. Corcoran
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Tucker v. Warden Belmont Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tucker-v-warden-belmont-correctional-institution-ohsd-2021.