Wolters v. Warden, Belmont Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedAugust 15, 2024
Docket2:23-cv-03988
StatusUnknown

This text of Wolters v. Warden, Belmont Correctional Institution (Wolters v. Warden, Belmont Correctional Institution) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wolters v. Warden, Belmont Correctional Institution, (S.D. Ohio 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

RON WOLTERS,

Petitioner, : Case No. 2:23-cv-03988

- vs - District Judge James L. Graham Magistrate Judge Michael R. Merz

WARDEN, Belmont Correctional Institution,

: Respondent. REPORT AND RECOMMENDATIONS

This habeas corpus pursuant to 28 U.S.C. § 2254 is before the Court for decision on the merits on the Petition (ECF No. 1), the State Court Record (ECF No. 7), the Return of Writ (ECF No. 8), and Petitioner’ Reply (ECF No. 15).

Litigation History

On February 26, 2020, Petitioner was indicted by the grand jury of Guernsey County, Ohio, on eight counts of rape and eight counts of gross sexual imposition (“GSI)(Indictment, State Court Record, ECF No. 7, Ex. 1). The trial jury convicted Wolters on three of the eight rape counts and all eight GSI charges. He was sentenced to three terms of imprisonment of twenty-five years to life on the rape counts, to be served consecutively, and five years on each of the GSI counts to be served concurrently with each other and with the rape sentences. Id. at Ex. 15. Wolters appealed to the Ohio Fifth District Court of Appeals which affirmed the conviction. State v. Wolters, 185 N.E.3d 601 (Ohio App. 5th Dist. Feb. 24, 2022), app. jurisdiction declined, 167 Ohio St.3d 1407 (2022). On October 24, 2022, Wolters filed an application to reopen under Ohio R. App. P. 26(B)(State Court Record, ECF No. 7, Ex. 23), which the Fifth District denied.

Id. at Ex. 24. The Ohio Supreme Court again declined to accept jurisdiction of an appeal. Id. at Ex. 27. On December 1, 2023, Wolters filed his Petition in this Court with the assistance of counsel, pleading the following grounds for relief: Ground 1: The State of Ohio failed to produce sufficient evidence to convict the appellant of the counts in the indictment in violation of his right to due process under the Fifth Amendment made applicable to all state criminal prosecutions by the Fourteenth Amendment to the federal constitution.

Ground 2: The trial court violated petitioner’s right to confrontation by allowing the alleged victim to testify via closed circuit.

Ground 3: Petitioner was denied effective assistance of counsel guaranteed by the Fifth, Sixth amendments made applicable to the State of Ohio by the Fourteenth Amendment to the federal constitution.

(Petition, ECF No. 1, PageID 7-13).

Analysis Ground One: Conviction on Insufficient Evidence

In his First Ground for Relief, Wolters asserts that the State failed to produce sufficient evidence to convict him on the three rape and eight GSI charges. An allegation that a verdict was entered upon insufficient evidence states a claim under the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Jackson v. Virginia, 443 U.S. 307 (1979); In re Winship, 397 U.S. 358 (1970); Johnson v. Coyle, 200 F.3d 987, 991 (6th Cir. 2000); Bagby v. Sowders, 894 F.2d 792, 794 (6th Cir. 1990)(en banc). In order for a conviction to be constitutionally sound, every element of the crime must be proved beyond a

reasonable doubt. In re Winship, 397 U.S. at 364. [T]he relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt . . . . This familiar standard gives full play to the responsibility of the trier of fact fairly to resolve conflicts in the testimony, to weigh the evidence and to draw reasonable inferences from basic facts to ultimate facts.

Jackson v. Virginia, 443 U.S. at 319; Smith v. Nagy, 962 F.3d 192, 205 (6th Cir. 2020) (quoting Jackson). This standard “must be applied with explicit reference to the substantive elements of the criminal offense as defined by state law.” Id. (quoting Jackson, 443 U.S. at 324). This rule was recognized in Ohio law at State v. Jenks, 61 Ohio St. 3d 259 (1991). Of course, it is state law which determines the elements of offenses; but once the state has adopted the elements, it must then prove each of them beyond a reasonable doubt. In re Winship, supra. A sufficiency challenge should be assessed against the elements of the crime, not against the elements set forth in an erroneous jury instruction. Musacchio v. United States, 577 U.S. 237 (2016). In cases such as Petitioner’s challenging the sufficiency of the evidence and filed after enactment of the Antiterrorism and Effective Death Penalty Act of 1996 (Pub. L. No 104-132, 110 Stat. 1214)(the “AEDPA”), two levels of deference to state decisions are required: In an appeal from a denial of habeas relief, in which a petitioner challenges the constitutional sufficiency of the evidence used to convict him, we are thus bound by two layers of deference to groups who might view facts differently than we would. First, as in all sufficiency-of-the-evidence challenges, we must determine whether, viewing the trial testimony and exhibits in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. See Jackson v. Virginia, 443 U.S. 307, 319, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979). In doing so, we do not reweigh the evidence, re- evaluate the credibility of witnesses, or substitute our judgment for that of the jury. See United States v. Hilliard, 11 F.3d 618, 620 (6th Cir. 1993). Thus, even though we might have not voted to convict a defendant had we participated in jury deliberations, we must uphold the jury verdict if any rational trier of fact could have found the defendant guilty after resolving all disputes in favor of the prosecution. Second, even were we to conclude that a rational trier of fact could not have found a petitioner guilty beyond a reasonable doubt, on habeas review, we must still defer to the state appellate court's sufficiency determination as long as it is not unreasonable. See 28 U.S.C. § 2254(d)(2).

Brown v. Konteh, 567 F.3d 191, 205 (6th Cir. 2009). In a sufficiency of the evidence habeas corpus case, deference should be given to the trier-of-fact's verdict under Jackson v. Virginia and then to the appellate court's consideration of that verdict, as commanded by AEDPA. Tucker v. Palmer, 541 F.3d 652 (6th Cir. 2008); accord Davis v. Lafler, 658 F.3d 525, 531 (6th Cir. 2011)(en banc); Parker v. Matthews, 567 U.S. 37, 43 (2012). Notably, “a court may sustain a conviction based upon nothing more than circumstantial evidence.” Stewart v. Wolfenbarger, 595 F.3d 647, 656 (6th Cir. 2010). We have made clear that Jackson claims face a high bar in federal habeas proceedings because they are subject to two layers of judicial deference. First, on direct appeal, "it is the responsibility of the jury -- not the court -- to decide what conclusions should be drawn from evidence admitted at trial. A reviewing court may set aside the jury's verdict on the ground of insufficient evidence only if no rational trier of fact could have agreed with the jury." Cavazos v. Smith, 565 U. S. 1, ___, 132 S. Ct. 2

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Elmendorf v. Taylor
23 U.S. 152 (Supreme Court, 1825)
In Re WINSHIP
397 U.S. 358 (Supreme Court, 1970)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Smith v. Phillips
455 U.S. 209 (Supreme Court, 1982)
Barclay v. Florida
463 U.S. 939 (Supreme Court, 1983)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Lewis v. Jeffers
497 U.S. 764 (Supreme Court, 1990)
Maryland v. Craig
497 U.S. 836 (Supreme Court, 1990)
Estelle v. McGuire
502 U.S. 62 (Supreme Court, 1991)
Bell v. Cone
535 U.S. 685 (Supreme Court, 2002)
Brown v. Payton
544 U.S. 133 (Supreme Court, 2005)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Wilson v. Corcoran
131 S. Ct. 13 (Supreme Court, 2010)
Brooks v. Tennessee
626 F.3d 878 (Sixth Circuit, 2010)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
United States v. John Thomas Terry
362 F.2d 914 (Sixth Circuit, 1966)
Davis v. Lafler
658 F.3d 525 (Sixth Circuit, 2011)
Cavazos v. Smith
132 S. Ct. 2 (Supreme Court, 2011)
United States v. Rockie Lane Hilliard
11 F.3d 618 (Sixth Circuit, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
Wolters v. Warden, Belmont Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wolters-v-warden-belmont-correctional-institution-ohsd-2024.