Williams v. Valley

District Court, D. Idaho·Decided March 4, 2025·No. 1:24-cv-00129·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

KENT WILLIAMS, Case No. 1:24-cv-00129-AKB Petitioner, MEMORANDUM DECISION AND v. ORDER

WARDEN VALLEY,

Respondent.

Pending before the Court is a Petition for Writ of Habeas Corpus filed by Idaho state prisoner Kent Williams (“Petitioner”), challenging Petitioner’s state court convictions. (See Dkt. 4). Respondent has filed a Motion for Partial Summary Dismissal, arguing that Claims 1 and 6 are noncognizable and that Claims 3(d), (e), (f), (h), (n), and (o), Claim 5, and Claim 6 are procedurally defaulted without excuse. (See Dkt. 22). The motion is now ripe for adjudication.1

1 Petitioner takes issue with the Court’s previous denial of his motion for extension of time to respond to the Motion for Partial Summary Dismissal. (See Dkt. 32 at 1–2). The Court denied Petitioner’s motion for a ninety-day extension because Petitioner refused to use the prison e-filing system and refused to serve Respondent with a copy of the motion. (See Dkt. 28). The Court explained to Petitioner how he could properly request an extension of time. (Id. at 3) (“If Petitioner needs an extension of time to respond to Respondent’s Motion for Partial Summary Dismissal, he must file a procedurally proper motion for such an extension, using the e-filing system if it is available and serving a copy of the motion on Respondent. If the e-filing system is unavailable— for example, because the internet at the prison is not working—then Petitioner may mail his motion to the Court, along with an affidavit or declaration explaining why the e-filing system was unavailable.”). Petitioner did not do so but, instead, simply filed his response without requesting such an extension. Thus, Petitioner cannot now complain that he lacked sufficient time to respond to the Motion for Partial Summary Dismissal. The Court takes judicial notice of the records from Petitioner’s state court proceedings, which have been lodged by Respondent. (Dkt. 21); see Fed. R. Evid. 201(b); Dawson v. Mahoney, 451 F.3d 550, 551 n.1 (9th Cir. 2006). Having carefully reviewed the record, including the state court record, the Court finds that oral argument is unnecessary. See D. Idaho L. Civ. R. 7.1(d). Accordingly, and for the reasons that

follow, the Court will enter the following Order granting the motion and dismissing Claim 1, Claims 3(d), (e), (f), (h), (n), and (o), Claim 5, and Claim 6 with prejudice. BACKGROUND The facts underlying Petitioner’s conviction are set forth clearly and accurately in State v. Williams, 411 P.3d 1186, 1191–93 (Idaho Ct. App. 2018). The facts will not be repeated here except as necessary to explain the Court’s decision. Following a jury trial in the Fourth Judicial District Court in Ada County, Idaho, Petitioner was convicted of two counts of bank robbery, one count of using a firearm in the commission of a robbery, and one count of unlawfully possessing a firearm. Williams, 411 P.3d at 1191. He was

sentenced to an aggregate unified term of life imprisonment with thirty-seven years fixed. State’s Lodging A-2 at 16–17. Petitioner filed a direct appeal. Appellate counsel originally raised two claims: that the trial court erred under state law by denying Petitioner’s motion to sever the two bank robbery charges and that the prosecutor committed misconduct by disparaging defense counsel and by vouching for police officers. State’s Lodging B-1. After appellate counsel withdrew (at Petitioner’s request) and Petitioner proceeded pro se, Petitioner initially raised five additional claims: that he was denied his Idaho state constitutional right to hybrid representation; that he should not have been restrained during the proceedings; that he was denied his right to represent himself; that the trial court should have suppressed certain evidence; and that the trial court should have granted Petitioner’s motion for substitute counsel or declared a mistrial. State’s Lodging B-9. However, Petitioner later sought leave to withdraw his claim regarding substitute counsel, and the Idaho Supreme Court granted the request. State’s Lodging B-12; B-13. The Idaho Court of Appeals affirmed Petitioner’s convictions, and the Idaho Supreme

Court denied review. State’s Lodging B-15; B-17. Petitioner then filed a pro se state post-conviction petition, asserting various claims of ineffective assistance of trial and appellate counsel, as well as claims that the prosecution presented false evidence and failed to disclose favorable evidence to the defense. State’s Lodging C-2 at 6– 7. Petitioner was then appointed counsel. Counsel attempted to amend the petition, but Petitioner refused to meet with counsel and refused to review the amended petition. State’s Lodging C-3 at 145–46. As a result of what the state district court described as Petitioner’s “intransigence in working with his appointed counsel,” an amended petition was never filed. Id. at 139. The state district court dismissed all of Petitioner’s post-conviction claims in two separate

orders. Id. at 755–75. Petitioner filed a pro se motion for relief from judgment under Idaho Rule of Civil Procedure 60(b), which the court denied because Petitioner was still represented by counsel. State’s Lodging C-5 at 26 (“Because Petitioner is represented by counsel, the Court cannot consider the motion unless filed through counsel.”). Petitioner appealed. After Petitioner complained about his post-conviction appellate counsel’s representation, counsel moved to withdraw. Id. at 37–39, 53–54, 56–188. The state court granted the motion to withdraw and appointed substitute appellate counsel. Id. at 199; State’s Lodging D-4. New appellate counsel filed an opening brief asserting ten claims of ineffective assistance of trial counsel, including a claim of cumulative prejudice. The brief also raised a claim of ineffective assistance of direct appeal counsel, a claim that the trial court deprived Petitioner of his right to represent himself, and two claims challenging the denial of Petitioner’s Rule 60(b) motion on state law grounds. State’s Lodging D-6. The Idaho Court of Appeals affirmed the dismissal of Petitioner’s post-conviction petition, and the Idaho Supreme Court denied review. State’s Lodging D-10; D-13.

In the instant federal habeas corpus petition, Petitioner asserts the following claims: Claim 1: Evidence was seized from Petitioner’s hotel room under an allegedly unlawful search warrant in violation of the Fourth Amendment. (See Dkt. 4 at 2).

Claim 2: Petitioner was denied his Sixth Amendment right to represent himself at trial due to the trial court’s decision regarding physical restraints. (Id.).

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