Ward v. Lumpkin

CourtDistrict Court, S.D. Texas
DecidedMarch 30, 2023
Docket4:21-cv-04119
StatusUnknown

This text of Ward v. Lumpkin (Ward v. Lumpkin) 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
Ward v. Lumpkin, (S.D. Tex. 2023).

Opinion

March 30, 2023 Nathan Ochsner, Clerk UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

KEVIN DEWAYNE § CIVIL ACTION NO WARD, § 4:21–cv–04119 (TDCJ–CID #633918) § Petitioner, § § § vs. § JUDGE CHARLES ESKRIDGE § § BOBBY LUMPKIN, § Respondent. § MEMORANDUM ON DISMISSAL The motion for summary judgment by Respondent Bobby Lumpkin is granted. Dkt 13. The petition for a writ of habeas corpus brought by Kevin Dewayne Ward is dismissed without prejudice. Dkt 1. His motion for summary judgment is denied. Dkt 15. 1. Background Ward pleaded nolo contendere to possession of cocaine and true to two enhancements for convictions in March 1992 in Cause Number 610932, before the 248th Judicial District Court of Harris County, Texas. The trial court sentenced him to thirty-five years in prison. Dkt 19-9 at 156. Ward was initially released to parole in October 2009. Dkt 13-1 at 3–4. This was revoked in December 2011. Id at 3–5. He was then released to parole again in October 2014. Id at 3, 5; Dkt 19-9 at 71. An arrest warrant was executed in Harris County in November 2020. Dkt 13-1 at 6. Ward received notice of his rights in the revocation process on November 6, 2020. Dkt 19-9 at 126. Ward’s parole revocation hearing was held on November 19, 2020. Id at 58. His parole was revoked on December 3, 2020. Id at 112. He was notified of the evidence relied on and the reasons for revocation on December 8, 2020. Id at 114. Ward filed a state application for a writ of habeas corpus in February 2021. Dkt 19-9 at 21. The Texas Court of Criminal Appeals denied it without written order in November 2021 on the findings of the trial court without a hearing and on the court’s own independent review of the record. Dkt 19-10 at 1. Ward proceeds here pro se. He filed this federal petition for a writ of habeas corpus in December 2021. Dkt 1. He contends that his parole revocation is illegal because his due process rights were violated when (i) he didn’t receive a preliminary parole revocation hearing; (ii) he was denied an attorney for his parole revocation hearing despite his history of treatment by the Harris Center, formerly the Mental Health and Mental Retardation Authority; and (iii) he wasn’t allowed to confront and cross-examine the adverse witness at his revocation hearing. Dkt 1 at 6–7. Respondent Bobby Lumpkin moves for summary judgment, arguing that Ward’s claims lack merit and must be dismissed. Dkt 13 at 6. He submits a number of exhibits as evidence. This includes the affidavit of Charlie Valdez, Program Supervisor III for the Classification and Records Department of the Texas Department of Criminal Justice—Correctional Institutions Division. Dkt 13, Exhibit A. Also submitted is a copy of Texas Government Code Sections 508.281 and 508.2811. Dkt 13, Exhibit B. Also included are the state habeas court records and an audio recording of the parole-revocation hearing. Dkts 14 & 19. 2. Legal standard a. AEDPA A pro se petition is construed liberally and isn’t held to the same stringent and rigorous standards as pleadings filed by lawyers. See Martin v Maxey, 98 F3d 844, 847 n 4 (5th Cir 1996); Bledsue v Johnson, 188 F3d 250, 255 2 (5th Cir 1999). But this doesn’t undo what AEDPA itself imposes as the standard of review on disputed questions of both law and fact. As to disputed questions of law, AEDPA bars federal relief based upon claims that were adjudicated on the merits by state courts unless the decision of the state court “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” or “was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” 28 USC § 2254(d); see also Early v Packer, 537 US 3, 7–8 (2002); Cobb v Thaler, 682 F3d 364, 372–73 (5th Cir 2012). The Fifth Circuit holds that a state-court decision is contrary to clearly established federal law “if it reaches a legal conclusion in direct conflict with a prior decision of the Supreme Court or if it reaches a different conclusion than the Supreme Court based on materially indistinguishable facts.” Gray v Epps, 616 F3d 436, 439 (5th Cir 2010), citing Williams v Taylor, 529 US 362, 404–08 (2002). And the Fifth Circuit holds that an unreasonable application of federal law means that the decision is “unreasonable, not merely wrong; even clear error will not suffice.” Escamilla v Stephens, 602 F Appx 939, 941 (5th Cir 2015, per curiam), quoting White v Woodall, 572 US 415, 419 (2014). This is a high bar. To surpass it, a petitioner must “show that the state court’s ruling on the claim being presented in federal court was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement.” Woods v Donald, 575 US 312, 316 (2015), quoting Harrington v Richter, 562 US 86, 103 (2011). As to disputed questions of fact, AEDPA precludes federal relief unless the adjudication by the state court of the merits was based on an “unreasonable determination of the facts in light of the evidence presented in the state court proceeding.” 28 USC § 2254(d)(2); see also Martinez v Caldwell, 644 F3d 238, 241–42 (5th Cir 2011). A state 3 court’s factual determinations are “presumed to be correct” unless the petitioner rebuts those findings with “clear and convincing evidence.” 28 USC § 2254(e)(1). This presumption of correctness extends not only to express factual findings, but also to implicit or “unarticulated findings which are necessary to the state court’s conclusion of mixed law and fact.” Murphy v Davis, 901 F3d 578, 597 (5th Cir 2018), quoting Valdez v Cockrell, 274 F3d 941, 948 n 11 (5th Cir 2001). A federal court reviewing a petition for writ of habeas corpus may only consider the factual record that was before the state court when determining the reasonableness of that court’s findings and conclusions. Cullen v Pinholster, 563 US 170, 180–81 (2011). And the Supreme Court instructs that the reviewing court “may not characterize these state-court factual determinations as unreasonable ‘merely because [it] would have reached a different conclusion in the first instance.’” Brumfield v Cain, 576 US 305, 313–14 (2015), quoting Wood v Allen, 558 US 290, 301 (2010). To the contrary, § 2254(d)(2) requires the federal court to “accord the state trial court substantial deference.” Brumfield, 576 US at 314. A petitioner seeking a writ of habeas corpus must also demonstrate injury of a certain character. To warrant relief based on state-court error, a petitioner must show the alleged error had “substantial and injurious effect.” Brecht v Abrahamson, 507 US 619 (1993); for example, see Hughes v Quarterman, 530 F3d 336, 345 (5th Cir 2008). This high bar isn’t met where evidence of the defendant’s guilt is overwhelming. Burgess v Dretke, 350 F3d 461, 472 (5th Cir 2003). There must be more than a mere reasonable possibility that it contributed to the verdict. Brecht, 507 US at 638. But where a court is confident that the error caused grave harm—or even if the record is evenly balanced in this regard—the petitioner is entitled to relief. See Fry v Pliler, 551 US 112 n 3 (2007), citing O’Neal v McAninch, 513 US 432, 435 (1995); see also Robertson v Cain, 324 F3d 297, 305 (5th Cir 2003). 4 b. AEDPA and Rule 56 The Fifth Circuit holds that Rule 56 of the Federal Rules of Civil Procedure “applies with equal force in the context of habeas corpus cases.” Clark v Johnson, 202 F3d 760, 764 (5th Cir 2000). But where Rule 56 and the rules governing habeas corpus petitions conflict, the latter controls.

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Related

Wood v. Allen
558 U.S. 290 (Supreme Court, 2010)
Lott v. Hargett
80 F.3d 161 (Fifth Circuit, 1996)
Martin v. Maxey
98 F.3d 844 (Fifth Circuit, 1996)
Singleton v. Johnson
178 F.3d 381 (Fifth Circuit, 1999)
Clark v. Johnson
202 F.3d 760 (Fifth Circuit, 2000)
Robertson v. Cain
324 F.3d 297 (Fifth Circuit, 2003)
Burgess v. Dretke
350 F.3d 461 (Fifth Circuit, 2003)
Hughes v. Quarterman
530 F.3d 336 (Fifth Circuit, 2008)
Morrissey v. Brewer
408 U.S. 471 (Supreme Court, 1972)
Gagnon v. Scarpelli
411 U.S. 778 (Supreme Court, 1973)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Ylst v. Nunnemaker
501 U.S. 797 (Supreme Court, 1991)
Brecht v. Abrahamson
507 U.S. 619 (Supreme Court, 1993)
O'NEAL v. McAninch
513 U.S. 432 (Supreme Court, 1995)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Early v. Packer
537 U.S. 3 (Supreme Court, 2002)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Fry v. Pliler
551 U.S. 112 (Supreme Court, 2007)
Gray v. Epps
616 F.3d 436 (Fifth Circuit, 2010)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)

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Ward v. Lumpkin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ward-v-lumpkin-txsd-2023.