White v. Warden, NHSP

2003 DNH 218P
CourtDistrict Court, D. New Hampshire
DecidedDecember 10, 2003
DocketCV-02-280-JM
StatusPublished

This text of 2003 DNH 218P (White v. Warden, NHSP) 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
White v. Warden, NHSP, 2003 DNH 218P (D.N.H. 2003).

Opinion

White v . Warden, NHSP CV-02-280-JM 12/10/03 P UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Delvin White

v. Civil N o . 02-280-JM Opinion N o . 2003 DNH 218P Jane Coplan, Warden, New Hampshire State Prison

O R D E R

Before the Court for consideration is Respondent’s motion

under Fed. R. Civ. P. 59(e) to alter the judgment in the above-

captioned matter (document n o . 1 4 ) . Petitioner has filed an

objection (document n o . 1 8 ) .

On July 9, 2002, the Petitioner filed a Petition for a Writ

of Habeas Corpus pursuant to 28 U.S.C. § 2254 attacking his state

court convictions on sexual assault charges. After this Court’s

preliminary review of the petition, the Respondent filed an

answer. Thereafter, the parties consented to the assignment of

this case to the United States Magistrate Judge, and Respondent

subsequently filed a motion for summary judgment.

The central issue in this case is whether the New Hampshire

state courts violated Petitioner’s rights under the Sixth

Amendment to the United States Constitution to cross-examine the complaining witnesses against him where the trial court found

that Petitioner could not cross-examine the complaining witnesses

regarding an alleged pattern of prior false allegations of

similar offenses against others even though Petitioner had

demonstrated the falsity of those prior allegations to a

reasonable probability. After reviewing the matter, this Court

issued an order on July 1 1 , 2003, denying Respondent’s motion for

summary judgment, and granting the Petitioner’s application for a

writ of habeas corpus (document n o . 1 2 ) .

The standard of review that the Court applied to the

consideration of the Petitioner’s federal constitutional claim

was of critical importance to the decision. Under the

Antiterrorism and Effective Death Penalty Act (“AEDPA”), Pub. L .

N o . 104-132, 110 Stat. 1214 (1996), the federal courts may not

grant a state prisoner a writ of habeas corpus with respect to

any claim that was adjudicated on the merits in state court

proceedings unless the adjudication of the claim:

(1) 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; or

(2) 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.

2 28 U.S.C. § 2254(d). There is no dispute that the Supreme Court

of the United States has not decided a case where it held that a

defendant’s Sixth Amendment right to cross-examine witnesses

requires the introduction of the type of evidence claimed to have

been wrongfully excluded in the Petitioner’s case. Therefore, if

Petitioner’s federal constitutional claim was adjudicated on the

merits in the state court proceedings, application of the

deferential standard of Section 2254(d)(1) would be fatal to the

Petitioner’s claim. That is so because federal law has not been

clearly established in Petitioner’s favor within the meaning of

the AEDPA. In this Court’s July 1 1 , 2003 Order, however, the

Court stated that:

In light of the NHSC’s express decision not to undertake a separate federal analysis of White’s federal claim, and the NHSC’s apparent reliance on state authorities that do not support its perfunctory dismissal of analysis of federal law, this Court finds that White’s federal constitutional claim was not adjudicated on the merits in the state court.

July 1 1 , 2003 Order at 1 0 . Since the Court found that there was

no adjudication of Petitioner’s federal constitutional claim in

the state court proceedings to which the Court should defer, the

Court further found Petitioner’s claim required de novo review

3 under First Circuit precedent. Id.1 Exercising its independent

judgment on de novo review, the Court found that the Supreme

Court’s Confrontation Clause jurisprudence reasonably extends to

cross-examination of adverse witnesses about a pattern of

allegedly false accusations against others of the type of offense

of which the defendant is accused in circumstances where the

defendant has demonstrated the falsity of those prior accusations

by a reasonable probability.

In her Rule 59(e) motion, Respondent urges the Court to

reconsider whether it was appropriate to apply de novo review in

this case. Finding that Respondent’s motion raises a serious

legal question, the Court re-examines that issue here before this

case makes its way to an almost certain appeal.

The Supreme Court’s decision in Early v . Packer, 537 U.S. 3

(2002), bears mention. In Early, the Court reversed a decision

of the Ninth Circuit in a habeas case in which the Ninth Circuit

observed that the state court had not cited the controlling

1 See Fryar v . Bissonnette, 318 F.3d 339, 340 (1st Cir. 2003) (finding that de novo review was required where the federal claim was properly presented, but had not been addressed by the state’s highest court); DiBenedetto v . Hall, 272 F.3d 1 , 6 (1st Cir. 2001) (finding that the AEDPA does not apply where the state court has not decided the federal constitutional issue); Fortini v . Murphy, 257 F.3d 3 9 , 47 (1st Cir. 2001) (AEDPA does not apply when the federal claim was not addressed by the state courts).

4 Supreme Court precedents on the relevant issue, nor indeed any

federal law. Id. at 8 . The Supreme Court found that a state

court need not cite, or even be aware o f , the Supreme Court’s

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

state-court decision contradicts them.” Id. In Ellsworth v .

Warden, N.H. State Prison, 333 F.3d 1 (1st Cir. 2003), the First

Circuit rejected an argument that Early invalidated the First

Circuit’s opinion in Fortini that the AEDPA does not apply when

the federal claim was not addressed by the state courts. The

First Circuit found that Early stands only for the proposition

that deference under the AEDPA does not depend on the state court

citing federal case law. Ellsworth, 333 F.3d at 4 n.1. Thus,

Fortini is ostensibly still good law.

Notwithstanding the First Circuit’s finding in Ellsworth,

however, the First Circuit has embraced a rule that greatly

restricts the application of Fortini. The court has found that

the adjudication of a habeas petitioner’s federal constitutional

claim should be deemed “subsumed” within the state court’s

adjudication of the petitioner’s state law claim if the state

court has held that the state adheres to a standard that is more

favorable to defendants than the applicable federal standard.

5 See Norton v . Spencer, N o . 03-1571, 2003 WL 22459121 at *3 (1st

Cir. Oct.

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Related

Davis v. Alaska
415 U.S. 308 (Supreme Court, 1974)
Early v. Packer
537 U.S. 3 (Supreme Court, 2002)
DiBenedetto v. Hall
272 F.3d 1 (First Circuit, 2001)
Fryar v. Bissonnette
318 F.3d 339 (First Circuit, 2003)
Norton v. Spencer
351 F.3d 1 (First Circuit, 2003)
United States v. John David Bartlett
856 F.2d 1071 (Eighth Circuit, 1988)
United States v. Stamper
766 F. Supp. 1396 (W.D. North Carolina, 1991)

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