Umana v. Davis

CourtDistrict Court, S.D. Texas
DecidedJune 2, 2020
Docket4:17-cv-01421
StatusUnknown

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

Bluebook
Umana v. Davis, (S.D. Tex. 2020).

Opinion

June 02, 2020 IN THE UNITED STATES DISTRICT COURT David J. Bradley, Clerk FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION PEDRO ERNESTO UMANA, § § Petitioner, § § v. § CIVIL ACTION NO. H-17-1421 § LORIE DAVIS, § § Respondent. § MEMORANDUM OPINION AND ORDER Petitioner, a state inmate proceeding pro se, filed this section 2254 habeas petition challenging his conviction and fifty-year sentence for aggravated sexual assault. Respondent filed a motion for summary judgment (Docket Entry No. 34), to which petitioner filed a response (Docket Entry No. 38). Having reviewed the motion, the response, the record, and the applicable law, the Court GRANTS the motion for summary judgment and DISMISSES this case for the reasons that follow. I. PROCEDURAL BACKGROUND AND CLAIMS A jury found petitioner guilty of aggravated sexual assault in Harris County, Texas, on February 22, 2013, and assessed punishment at fifty years’ incarceration. The conviction was affirmed on appeal, Umana v. State, 447 S.W.3d 346 (Tex. App.—Houston [14th Dist.] 2014, pet. ref’d), and discretionary review was refused. Petitioner’s application for state habeas relief was denied by the Texas Court of Criminal Appeals in August 2016. Petitioner raises the following claims for relief in this federal habeas petition: 1. His videotaped pretrial statement was involuntary.

2. Trial counsel was ineffective in not pursuing an insanity defense. 3. His pretrial statement was improperly admitted. 4. Trial counsel was ineffective in not properly arguing the motion to suppress. Respondent argues that these claims should be dismissed as procedurally defaulted and/or without merit. II. FACTUAL BACKGROUND

The intermediate state court of appeals set forth the following statement of facts in its opinion affirming petitioner’s conviction: The complainant and two friends were at her apartment when three people forced their way in with a handgun. The intruders were subsequently identified as [petitioner], his sister and her husband. [Petitioner] held the complainant and her friends at gunpoint while the intruders ransacked the apartment. [Petitioner] directed the complainant into her bedroom while holding her at gunpoint and sexually assaulted her. The investigation led police to [petitioner]. Approximately 16 hours after the robbery and assault, [petitioner] waived his rights and gave a statement to police that was recorded on video. Three days later, a judge ordered a psychological review of the [petitioner], as [petitioner] self-reported that he was hearing voices telling him to do bad things and had a prior diagnosis of bipolar disease and schizophrenia. [Petitioner] received medication while in custody. Five months after the offense, [petitioner] was evaluated for competency by Dr. Stephen McCary pursuant to court order. Dr. McCary found [him] incompetent to stand trial. [Petitioner] was admitted to North Texas State Hospital for psychiatric treatment. 2 Fourth months later, Dr. Jennifer L. Russell evaluated [petitioner] and found he was competent to stand trial. The trial court found [his] competency had been restored on November 20, 2011, and his trial began the following September. [Petitioner] filed a motion to suppress his video-taped statement on the grounds he was unable to voluntarily waive his rights because he was mentally ill. Following a hearing, the trial court denied [petitioner’s] motion and the video-taped statement was admitted into evidence and played to the jury. Umana, 447 S.W.3d at 349. III. LEGAL STANDARDS A. Habeas Review This petition is governed by the applicable provisions of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). 28 U .S.C. § 2254. Under the AEDPA, federal habeas relief cannot be granted on legal issues adjudicated on the merits in state court unless the state adjudication was contrary to clearly established federal law as determined by the Supreme Court, or involved an unreasonable application of clearly established federal law as determined by the Supreme Court. Harrington v. Richter, 562 U.S. 86, 98–99 (2011); Williams v. Taylor, 529 U.S. 362, 404–05 (2000); 28 U.S.C. §§ 2254(d)(1), (2). A state court decision is contrary to federal precedent if it applies a rule that contradicts the governing law

set forth by the Supreme Court, or if it confronts a set of facts that are materially indistinguishable from such a decision and arrives at a result different from the Supreme Court’s precedent. Early v. Packer, 537 U.S. 3, 7–8 (2002).

3 A state court unreasonably applies Supreme Court precedent if it unreasonably applies the correct legal rule to the facts of a particular case, or 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, 529 U.S. at 409. In deciding whether a state court’s application was unreasonable, this Court considers whether the application was objectively unreasonable. Id. at 411. “It bears repeating that even a strong case for relief does not mean the state court’s contrary

conclusion was unreasonable.” Richter, 562 U.S. at 102. As stated by the Supreme Court in Richter, If this standard is difficult to meet, that is because it was meant to be. As amended by AEDPA, § 2254(d) stops short of imposing a complete bar on federal court relitigation of claims already rejected in state proceedings. It preserves authority to issue the writ in cases where there is no possibility fairminded jurists could disagree that the state court’s decision conflicts with this Court’s precedents. It goes no farther. Section 2254(d) reflects the view that habeas corpus is a “guard against extreme malfunctions in the state criminal justice systems,” not a substitute for ordinary error correction through appeal. Id., at 102–03 (emphasis added; internal citations omitted). The AEDPA affords deference to a state court’s resolution of factual issues. Under 28 U.S.C. § 2254(d)(2), a decision adjudicated on the merits in a state court and based on a factual determination will not be overturned on factual grounds unless it is objectively unreasonable in light of the evidence presented in the state court proceeding. Miller–El v. Cockrell, 537 U.S. 322, 343 (2003). A federal habeas court must presume the underlying 4 factual determination of the state court to be correct, unless the petitioner rebuts the presumption of correctness by clear and convincing evidence. 28 U.S.C. § 2254(e)(1); see

also Miller–El, 537 U.S. at 330–31. B. Summary Judgment In deciding a motion for summary judgment, the district court must determine whether the pleadings, discovery materials, and the summary judgment evidence show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as

a matter of law. FED. R. CIV. P. 56(c). Once the movant presents a properly supported motion for summary judgment, the burden shifts to the nonmovant to show with significant probative evidence the existence of a genuine issue of material fact. Hamilton v. Segue Software, Inc., 232 F.3d 473, 477 (5th Cir. 2000).

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Bluebook (online)
Umana v. Davis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/umana-v-davis-txsd-2020.