Washington v. Cool

District Court, N.D. Ohio·Decided August 29, 2025·No. 3:22-cv-01634·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

DARIUS WASHINGTON, ) Case No. 3:22-cv-1634 ) Petitioner, ) Judge J. Philip Calabrese ) v. ) Magistrate Judge ) Jennifer D. Armstrong WILLIAM COOL, Warden, ) ) Respondent. ) )

OPINION AND ORDER Petitioner Darius Washington, a prisoner in State custody, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254. The Magistrate Judge recommends denying and dismissing Petitioner’s claims. Petitioner objects to that recommendation. For the following reasons, the Court OVERRULES Petitioner’s objections, ADOPTS the Magistrate Judge’s Report and Recommendation, and DENIES and DISMISSES the petition for a writ of habeas corpus. Further, the Court DECLINES to issue a certificate of appealability. FACTUAL AND PROCEDURAL BACKGROUND This petition for writ of habeas corpus arises from a conviction in State court. Unless the habeas petitioner demonstrates otherwise with clear and convincing evidence, federal courts presume that a State court’s findings of fact are correct. Moore v. Mitchell, 708 F.3d 760, 775 (6th Cir. 2013). A. Indictment, Trial, and Conviction. On March 28, 2019, a grand jury indicted Darius Washington on the following charges: two first-degree felony counts of rape under Sections 2907.02(A)(2) and

2907.02(B) of the Ohio Revised Code; two second-degree felony counts of felonious assault with a sexual motivation specification under Sections 2907.02(A)(2), 2907.02(B), and 2941.147; and two first-degree felony counts of kidnapping with a sexual motivation specification under Sections 2905.01(A)(4), 2905.01(C), and 2941.147. (ECF No. 7-1, PageID #105–08.) The charges account for Mr. Washington’s actions with two different women on two separate days. (Id.) At a pre-trial hearing in the State trial court on June 6, 2019, Petitioner made

an oral motion for substitution of counsel, which was denied. (Id., PageID #464.) At another pre-trial hearing on July 12, 2019, Mr. Washington made another oral motion for substitution of counsel. (Id., PageID #113.) Mr. Washington repeatedly interrupted the judge, his own counsel, and prosecutors during the hearing. (Id., PageID #402.) The deputy sheriff forced Mr. Washington to sit in a chair “for safety and security reasons,” and he “was warned that obstreperous conduct would result in

his removal from the courtroom.” (Id.) Eventually, he was escorted out of the courtroom. (ECF No. 7-2, PageID #492.) On July 15, 2019, the State trial court denied the motion for substitution of counsel because of appointed counsel’s “vast experience in handling criminal trials.” (ECF No. 7-1, PageID #121.) At the beginning of the trial on July 16, 2019, the State trial court asked Mr. Washington if he would behave in a manner more conducive to courtroom decorum. (ECF No. 7-2, PageID #493–95.) Mr. Washington responded to these questions by stating that he did not want his attorney to represent him, which resulted in a prolonged discussion about the issue. (Id., PageID #494–500.) The State trial court stated that it had already addressed the matter. (Id., PageID #500.)

Eventually, because Mr. Washington did not agree to comply with courtroom decorum and did not drop the issue regarding substitution of counsel, the State trial court forced Mr. Washington to view the first day of trial from his holding cell, where he was able to hear the proceedings and communicate with his lawyer by phone. (Id., PageID #500, #683, & #940–41.) Mr. Washington was present in the courtroom for the rest of the trial. (Id., PageID #719.)

On July 19, 2019, the jury found Mr. Washington guilty on all counts. (ECF No. 7-1, PageID #122.) At his sentencing hearing, counsel for Mr. Washington argued that the State trial court should merge his counts. (Id., PageID #123; ECF No. 7-2, PageID #1026.) The court rejected this argument and sentenced him to twenty-eight years in prison. (ECF No. 7-1, PageID #123–24.) B. Direct Appeal Through new appellate counsel, Mr. Washington raised one assignment of

error on appeal: “The trial court erred in failing to merge Counts 2 and 3 with Count 1 and Counts 5 and 6 with Count 4.” (Id., PageID #139.) On the basis of conduct on June 25, 2018 with one of the victims, Counts 1, 2, and 3 charged Mr. Washington with, respectively: rape, felonious assault with a specification of sexual motivation, and kidnapping with a specification of sexual motivation. (Id., PageID #105–06.) On the basis of conduct on August 17, 2018 involving a different victim, Counts 4, 5, and 6 charge Mr. Washington with the same offenses: rape, felonious assault with a specification of sexual motivation, and kidnapping with a specification of sexual motivation. (Id., PageID #106–08.) After the State responded to his brief, Mr. Washington replied and raised three

new assignments of error: (1) “The trial court erred in barring appellant from the courtroom during critical stages of appellant’s jury trial thereby violating appellant’s right to due process and right to confront witnesses”; (2) the “Appellant was denied effective assistance of counsel at all critical stages of his trial”; and (3) “The jury’s verdict was against the manifest weight of evidence.” (Id., PageID #173.) On March 12, 2021, the State appellate court determined that the trial court

did not err in failing to merge Counts 2 and 3 with Count 1 or Counts 5 and 6 with Count 4. (Id., PageID #185 & #195–96.) The court reasoned that Counts 2 and 3 should not merge with Count 1 because they were of a dissimilar import, meeting the requirement for a conviction of distinct offenses under Section 2941.25(B) of the Ohio Revised Code. (Id., ¶¶ 23–26, PageID #192–93; see State v. Ruff, 143 Ohio St. 3d 114, 2015-Ohio-995, 34 N.E.3d 892, ¶ 13.) Similarly, the State appellate court determined that Counts 5 and 6 should not merge with Count 4 because they were committed by

separate acts. (Id., ¶ 33, PageID #195–96.) If offenses are committed separately, Section 2941.25(B) permits a conviction a defendant for multiple, distinct offenses. (Id., PageID #191.) Also, the appelate court struck Mr. Washington’s reply brief because the Ohio Rules of Appellate Procedure do not permit appellants to present assignments of error in a reply brief. (Id., PageID #190 n.1.) On April 22, 2021, Mr. Washington, proceeding pro se, filed a notice of appeal to the Ohio Supreme Court. (Id., PageID #197.) In his memorandum in support of jurisdiction, Mr. Washington raised one issue, relating to the merger of the counts at

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