Wall v. Davis

CourtDistrict Court, D. Idaho
DecidedFebruary 25, 2022
Docket1:21-cv-00445
StatusUnknown

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

Bluebook
Wall v. Davis, (D. Idaho 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

ROBROY WALL JR., Case No. 1:21-cv-00445-DCN Petitioner, INITIAL REVIEW ORDER vs.

WARDEN DAVIS,

Respondents.

Petitioner Robroy Wall Jr. has filed a Petition for Writ of Habeas Corpus challenging his state court conviction. Dkt. 3. Federal habeas corpus relief is available to petitioners who are held in custody under a state court judgment that violates the Constitution, laws, or treaties of the United States. See 28 U.S.C. § 2254(a). The Court is required to review each newly-filed habeas corpus petition to determine whether it should be served upon the respondent, amended, or summarily dismissed. See 28 U.S.C. § 2243. If “it plainly appears from the face of the petition and any attached exhibits that the petitioner is not entitled to relief in the district court,” the petition will be summarily dismissed. Rule 4 of the Rules Governing Section 2254 Cases. Having reviewed the Petition, the Court concludes that Petitioner may proceed to the next stage of litigation in this matter. REVIEW OF PETITION 1. Background Petitioner was convicted of murder after a jury trial in a criminal trial in the Fourth Judicial District Court in Ada County, Idaho. He was sentenced to 25 years of incarceration, with life indeterminate. Petitioner filed a direct appeal after conviction and three post-conviction actions in state court, with attendant appeals. Ultimately unsuccessful

in overturning his convictions and sentences in state court, Petitioner now petitions the federal court for habeas corpus relief. 2. Discussion In the Petition for Writ of Habeas Corpus, Petitioner raises several claims. Claim One(a) appears to be based on ineffective assistance of post-conviction counsel, which is

not a cognizable claim in itself, but, if proven, can act as a gateway for the Court to hear otherwise procedurally-barred claims, here, ineffective assistance of direct appeal counsel and trial counsel. Pennsylvania v. Finley, 481 U.S. 551 (1987) (holding that a petitioner does not have a federal constitutional right to effective assistance of counsel during state post-conviction proceedings); Bonin v. Vasquez, 999 F.2d 425, 430 (9th Cir. 1993).

Petitioner alleges that post-conviction counsel failed to raise claims that direct appeal counsel was ineffective for failure to raise claims of prosecutorial misconduct and actual innocence. Dkt. 3, pp. 12-17. Petitioner also alleges that post-conviction counsel failed to raise a claim that trial counsel “was not merely ineffective but actually detrimental to the defense.” Id., p.22. Rather than present these claims in terms of ineffective assistance

of post-conviction counsel, Petitioner should file an amended petition raising the actual direct appeal counsel and trial counsel claims that post-conviction counsel failed to raise on post-conviction review, omitting any claim that post-conviction counsel was ineffective, but asserting that Petitioner plans to rely on ineffective assistance of post-conviction counsel for the default of the trial counsel claims via the Martinez v. Ryan exception (explained below), and he plans to rely on the actual innocence/miscarriage of justice exception for the default of the direct appeal counsel claims and the trial counsel claims.

Claim One(b) appears to be an ineffective assistance of trial counsel as to various pieces of evidence that showed Petitioner’s actual innocence of the crime charged. Id., pp. 26-32. Claim One(c) appears to be trial counsel’s failure to prepare or present any sort of defense at trial. Id., p. 32. These are cognizable claims. Claim Two is “actual and factual innocence.” The United States Supreme Court has

determined that a claim of actual innocence cannot be raised in a federal habeas corpus action. Herrera v. Collins, 506 U.S. 390, 404-05 (1993). However, as explained below, even though actual innocence is not itself a constitutional claim, it may be used to excuse the procedural default or untimeliness of other cognizable habeas corpus claims. For example, if Petitioner’s successive post-conviction petitions were dismissed on procedural

grounds, they will not serve to toll the federal statute of limitations, as explained below, but Petitioner may assert actual innocence to excuse untimeliness. Claim Three(a) is that conviction of a totally innocent person violates the Eighth Amendment. Claim Three(b) is that conviction of the innocent violates the Due Process Clause. Dkt. 3, pp. 41-42. These arguments were rejected in Herrera on factual grounds,1

1 In Herrera, the Supreme Court reasoned:

We may assume, for the sake of argument in deciding this case, that in a capital case a truly persuasive demonstration of “actual innocence” made after trial would render the execution of a defendant unconstitutional, and warrant federal habeas relief if there were no state avenue open to process such a claim. But because of the very disruptive effect that and so Petitioner may proceed to the next stage of litigation so that the Court may examine his proffered facts if he overcomes any procedural hurdles. Claim Four is that the prosecutor committed misconduct when Petitioner was

convicted solely on the testimony of co-defendant Dan Hosford. Id., p. 43-52. This is a cognizable claim. If the Court has misconstrued any of these claims, Petitioner should clarify his claims in his amended petition. 3. Standards of Law

Given Petitioner’s status as a pro se litigant, the Court provides the following habeas corpus standards of law which may apply to Petitioner’s case, depending on Respondent’s response. A. Exhaustion of State Court Remedies Habeas corpus law requires that a petitioner “exhaust” his state court remedies

before pursuing a claim in a federal habeas petition. 28 U.S.C. § 2254(b). To exhaust a claim, a habeas petitioner must fairly present it as a federal claim to the highest state court for review in the manner prescribed by state law. See O’Sullivan v. Boerckel, 526 U.S. 838,

entertaining claims of actual innocence would have on the need for finality in capital cases, and the enormous burden that having to retry cases based on often stale evidence would place on the States, the threshold showing for such an assumed right would necessarily be extraordinarily high. The showing made by petitioner in this case falls far short of any such threshold.

506 U.S. at 417. But see Justice O’Connor’s concurrence: “[T]he issue before us is not whether a State can execute the innocent. It is, as the Court notes, whether a fairly convicted and therefore legally guilty person is constitutionally entitled to yet another judicial proceeding in which to adjudicate his guilt anew, 10 years after conviction, notwithstanding his failure to demonstrate that constitutional error infected his trial.” Id. at 420 (O’Connor, J., concurring). 845 (1999). Unless a petitioner has exhausted his state court remedies relative to a particular claim, a federal district court cannot grant relief on that claim, although it does have the discretion to deny the claim. 28 U.S.C. § 2254(b)(2).

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Related

United States v. Frady
456 U.S. 152 (Supreme Court, 1982)
Murray v. Carrier
477 U.S. 478 (Supreme Court, 1986)
Pennsylvania v. Finley
481 U.S. 551 (Supreme Court, 1987)
Teague v. Lane
489 U.S. 288 (Supreme Court, 1989)
McCleskey v. Zant
499 U.S. 467 (Supreme Court, 1991)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Sawyer v. Whitley
505 U.S. 333 (Supreme Court, 1992)
Herrera v. Collins
506 U.S. 390 (Supreme Court, 1993)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Edwards v. Carpenter
529 U.S. 446 (Supreme Court, 2000)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Bonin v. Vasquez
999 F.2d 425 (Ninth Circuit, 1993)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
Charles Tyree Green v. Theo White, Warden
223 F.3d 1001 (Ninth Circuit, 2000)
Mark Steven Van Buskirk v. George H. Baldwin
265 F.3d 1080 (Ninth Circuit, 2001)
McQuiggin v. Perkins
133 S. Ct. 1924 (Supreme Court, 2013)

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Wall v. Davis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wall-v-davis-idd-2022.