Wamala v. NHSP Warden

2011 DNH 017
CourtDistrict Court, D. New Hampshire
DecidedJanuary 28, 2011
Docket10-CV-87-SM
StatusPublished

This text of 2011 DNH 017 (Wamala v. NHSP Warden) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wamala v. NHSP Warden, 2011 DNH 017 (D.N.H. 2011).

Opinion

Wamala v . NHSP Warden 10-CV-87-SM 1/28/11 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Severine Wamala, Plaintiff

v. Case N o . 10-cv-87-SM Opinion N o . 2011 DNH 017 Larry Blaisdell, Warden, Northern New Hampshire Correctional Facility, Defendant

O R D E R

In September of 2007, Severine Wamala was convicted of

eleven counts of aggravated felonious sexual assault upon his

then 14-year old daughter, J.W. Wamala was sentenced to two

consecutive terms of ten to twenty years of imprisonment and, on

appeal to the New Hampshire Supreme Court, his convictions were

affirmed. State v . Wamala, 158 N.H. 583 (2009). Wamala now

seeks federal habeas corpus relief, asserting that his Fifth,

Sixth, and Fourteenth Amendment rights were violated during his

trial. See Report and Recommendation (document n o . 4 ) at 3-4

(construing petitioner’s claims). See generally 28 U.S.C. §

2254.

The State denies that any of Wamala’s constitutional rights

were violated and moves for summary judgment. For the reasons

discussed below, the State’s motion is granted. Standard of Review

I. Habeas Corpus Generally.

Since passage of the Anti-Terrorism and Effective Death

Penalty Act of 1996 (“AEDPA”), 28 U.S.C. § 2254(d), the power to

grant federal habeas relief to a state prisoner with respect to

claims adjudicated on the merits in state court has been

substantially limited. A federal court may not disturb a state

conviction unless the state court’s adjudication “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.” 28 U.S.C. § 2254(d)(2). And, a habeas petitioner

seeking relief under that provision faces a substantial burden

insofar as “a determination of a factual issue made by a State

court shall be presumed to be correct.” 28 U.S.C. § 2254(e)(1).

Alternatively, habeas relief may be granted if the state

court’s resolution of the constitutional issues before it

“resulted in a decision that was contrary t o , or involved an

unreasonable application o f , clearly established Federal law, as

determined by the Supreme Court of the United States.” 28 U.S.C.

§ 2254(d)(1). See also Williams v . Taylor, 529 U.S. 362, 399

(2000). The Supreme Court explained the distinction between

decisions that are “contrary to” clearly established federal law,

2 and those that involve an “unreasonable application” of that law

as follows:

Under the “contrary to” clause, a federal habeas court may grant the writ if the state court arrives at a conclusion opposite to that reached by [the Supreme] Court on a question of law or if the state court decides a case differently than [the Supreme] Court has on a set of materially indistinguishable facts. Under the “unreasonable application” clause, a federal habeas court may grant the writ if the state court identifies the correct governing legal principle from [the Supreme] Court’s decisions but unreasonably applies that principle to the facts of the prisoner’s case.

Williams, 529 U.S. at 412-13. The Court also noted that an

“incorrect” application of federal law is not necessarily an

“unreasonable” one.

The most important point is that an unreasonable application of federal law is different from an incorrect application of federal law . . . . Under § 2254(d)(1)’s “unreasonable application” clause, then, a federal habeas court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly. Rather, that application must also be unreasonable.

Id. at 410-11 (emphasis in original).

Finally, it probably bears noting that a state court need

not rely upon, nor need it even cite, Supreme Court precedent in

order to avoid resolving a petitioner’s claims in a way that is

3 “contrary to” or involves an “unreasonable application of”

clearly established federal law. See Early v . Packer, 537 U.S.

3 , 8 (2002) (“Avoiding these pitfalls does not require citation

of our cases - indeed, it does not even require awareness of our

cases, so long as neither the reasoning nor the result of the

state-court decision contradicts them.”) (emphasis in original).

In fact, even when a state court has summarily rejected a

petitioner’s federal claim without any discussion at all, “it may

be presumed that the state court adjudicated the claim on the

merits in the absence of any indication or state-law procedural

principles to the contrary.” Harrington v . Richter, __ U.S. __,

2011 WL 148587 at *9 (Jan. 1 9 , 2011). Under those circumstances

- that i s , when “a state court’s decision is unaccompanied by an

explanation,” - the habeas petitioner still bears the burden of

“showing there was no reasonable basis for the state court to

deny relief.” Id.

Only as to federal claims that were not adjudicated on the

merits by the state court, may this court apply the more

petitioner-friendly de novo standard of review. See, e.g.,

Clements v . Clarke, 592 F.3d 45 52 (1st Cir. 2010) (“In contrast,

a state court decision that does not address the federal claim on

the merits falls beyond the ambit of AEDPA. When presented with

4 such unadjudicated claims, the habeas court reviews them de

novo.”) (citation omitted).

With those principles in mind, the court turns to Wamala’s

petition and the State’s motion for summary judgment.

Factual Background

Most of the relevant facts leading up to Wamala’s arrest, as

well as those concerning pre-trial motions practice and the

criminal trial itself, are summarized (with record citations) in

the State’s legal memorandum (document n o . 22-1) and Wamala’s

objection (document n o . 2 6 - 1 ) . The parties are familiar with the

relevant facts and those central to Wamala’s habeas petition are

not (or cannot reasonably be) disputed. Accordingly, a lengthy

recitation of the factual background is not necessary. Those

facts relevant to the disposition of this matter are discussed as

appropriate.

Discussion

As construed by the magistrate judge, Wamala’s petition

advances five properly exhausted claims:

1. Wamala’s Sixth and Fourteenth Amendment rights to a speedy trial were violated when, over Wamala’s repeated assertions of his speedy trial rights and demands for a

5 speedy trial, he was subjected to a pretrial delay of twelve months, while he was detained awaiting trial, unable to post the $1,000,000 bail set by the trial court.

2. Wamala’s Fifth and Fourteenth Amendment rights to due process and equal protection were violated when he was denied attorney-conducted individual voir dire during the selection of his jury.

3.

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Tome v. United States
513 U.S. 150 (Supreme Court, 1995)
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537 U.S. 3 (Supreme Court, 2002)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Evans v. Verdini
466 F.3d 141 (First Circuit, 2006)
United States v. Volungus
595 F.3d 1 (First Circuit, 2010)
Clements v. Clarke
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2011 DNH 017, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wamala-v-nhsp-warden-nhd-2011.