Wood v. Warden Noble Correctional Institution

CourtDistrict Court, S.D. Ohio
DecidedFebruary 11, 2025
Docket2:23-cv-03275
StatusUnknown

This text of Wood v. Warden Noble Correctional Institution (Wood v. Warden Noble 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
Wood v. Warden Noble Correctional Institution, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION Scott Wood, Petitioner, Case No. 2:23-cv-3275 V. Judge Michael H. Watson Warden, Noble Correctional Institution, Magistrate Judge Merz Respondent. OPINION AND ORDER Scott Wood (“Petitioner”) petitioned for a writ of habeas corpus, raising three grounds (four claims) for relief. Petition, ECF No. 1. The Magistrate Judge issued a Report and Recommendation (“R&R”) and a supplement thereto (“Supp. R&R”), recommending the Court dismiss Petitioner’s petition as procedurally defaulted. R&R, ECF No. 28; Supp. R&R, ECF No. 31. Petitioner timely objects. Obj., ECF No. 29; Obj., ECF No. 32. I. STANDARD OF REVIEW Pursuant to Federal Rule of Civil Procedure 72(b), the Court determines “de novo any part of the magistrate judge’s disposition that has been properly objected to.” ll. © PROCEDURAL HISTORY Petitioner was convicted of various drug crimes and sentenced in the Perry County Court of Common Pleas. Ex. 20, ECF No. 15 at PAGEID # 144-54. He

directly appealed his conviction and sentence to the Ohio Fifth District Court of Appeals (“Fifth District”). Ex. 22, ECF No. 15 at PAGEID # 162. Petitioner raised four assignments of error on direct appeal: (1) the verdicts “were not supported by sufficient evidence and were also against the manifest weight of the evidence”; (2) “the trial court erred . . . by imposing additional prison terms for being a major drug offender; (3) “the trial court erred . . . by overruling [Petitioner’s] motion to suppress evidence”; and (4) Ohio’s statutory scheme for indefinite prison terms violated Petitioner’s state and federal due process rights. Ex. 23, ECF No. 15 at PAGEID # 167 (cleaned up). The Fifth District “affirmed in part and vacated in part” the judgment. Ex. 25, ECF No. 15 at PAGEID # 209-23. Specifically, it affirmed Petitioner's convictions but vacated his sentence and remanded for re-sentencing, concluding the trial court violated an Ohio statute by enhancing Petitioner’s sentence for being a major drug offender. See generally id. Petitioner was resentenced in common pleas court without the enhancement. Ex. 26, ECF No. 15 at PAGEID # 225-30. Petitioner did not appeal the re-sentencing to the Fifth District. But, several months later, he filed a notice of appeal and moved for leave to file a delayed appeal in the Supreme Court of Ohio, seeking to belatedly appeal the Fifth District's decision.1_ Ex. 27, ECF No. 15 at PAGEID # 231-32; Ex. 28, ECF

1 In the period between the re-sentencing and the motion for delayed appeal, it seems Petitioner attempted to appeal the Fifth District’s decision, but the Supreme Court of Case No. 2:23-cv-3275 Page 2 of 19

No. 15 at PAGEID # 233-39. The Supreme Court of Ohio granted Petitioner’s motion for a delayed appeal and ordered Petitioner to file his memorandum in support of jurisdiction by May 11, 2023. Ex. 29, ECF No. 15 at PAGEID # 263. The Court did not timely receive said memorandum and dismissed the appeal for failure to prosecute. Ex. 30, ECF No. 15 at PAGEID # 264. Petitioner later moved again to file a delayed appeal, but the Supreme Court of Ohio denied the motion. Ex. 31, ECF No. 15 at PAGEID # 265-66; Ex. 32, ECF No. 15 at PAGEID # 267-89; Ex. 33, ECF No. 15 at PAGEID # 290. lll. ANALYSIS Before beginning the analysis, it helps to set forth Petitioner’s federal grounds for relief and explain how they differ from the claims raised on direct appeal. In Ground One of the habeas petition, Petitioner alleges he was convicted based on insufficient evidence and against the manifest weight of the evidence. Petition at 4, ECF No. 1. The Court construes those as separate claims. Ground Two argues the trial court violated Petitioner’s Eighth and Fourteenth Amendment rights by imposing additional prison terms under Ohio’s major drug offender laws. Id. at 4—5. Ground Three argues the trial court violated Petitioner’s Fourth Amendment rights when it failed to suppress unlawfully obtained evidence.

Ohio rejected the notice of appeal as untimely. Compare S. Ct. Prac. R. 7.01(A)(1)(a)(i) (setting forty-five-day deadline for jurisdictional appeal), with Ex. 27, ECF No. 15 at PAGEID # 231 (noting Nov. 17, 2022 “Received” stamp). Case No. 2:23-cv-3275 Page 3 of 19

Although several of Petitioner's later filings reference the Sixth Amendment, his petition does not contain an ineffective assistance of counsel claim. Petitioner’s petition differs from his direct appeal in two ways. First, Petitioner raised a federal due process claim based on Ohio’s scheme of indefinite prison terms on direct appeal but did not include it in his habeas petition. Second, as will be shown below, the basis for Petitioner’s “major drug offender’ claim on direct appeal was state law, but he alleges a violation of federal law in his habeas petition. A. Two of Petitioner’s Claims Fail on the Merits, Obviating the Need to Analyze Procedural Default. Respondent has raised procedural default as a defense to each of Petitioner’s claims, but “[t]he U.S. Supreme Court has held that federal courts are not required to address a procedural-default issue before deciding against the petitioner on the merits.” Hudson v. Jones, 351 F.3d 212, 215 (6th Cir. 2003) (citation omitted). Here, the procedural default analysis of Petitioner’s “manifest weight of the evidence” and Fourth Amendment claims is complicated, so the Court elects to forgo it and turn directly to the merits. 1. Manifest Weight of the Evidence Aclaim that a defendant was convicted against the manifest weight of the evidence is “not a federal constitutional claim” and is thus not cognizable on

Case No. 2:23-cv-3275 Page 4 of 19

habeas review. Johnson v. Havener, 534 F.2d 1232, 1234 (6th Cir. 1986).? This claim therefore fails. 2. Unlawful Search and Seizure Although the Fourth Amendment protects against unlawful searches and seizures, U.S. Const. amend. IV, not all violations warrant habeas review. Indeed, “the Constitution does not require that a state prisoner be granted federal habeas corpus relief on the ground that evidence obtained in an unconstitutional search or seizure was introduced at his trial”? so long as “the State has provided an opportunity for full and fair litigation of a Fourth Amendment claim[.]” Stone v. Powell, 428 U.S. 465, 482 (1976). Thus, a Fourth Amendment claim‘ is cognizable on habeas review only if “the state provided no procedure by which the prisoner could raise his Fourth Amendment claim, or the prisoner was foreclosed from using that procedure.” Cotham v. Boyd, No. 24-5343, 2024 WL 4541532, at *3 (6th Cir. Sept. 19, 2024)

2 See Hoffman v. Lazaroff, No. 18-3439, 2018 WL 5849894, at *3 (6th Cir. Sept. 17, 2018), for a fuller explanation of why “insufficiency of the evidence” claims are cognizable on habeas but “manifest weight of the evidence” claims are not. 3 This is because the exclusionary rule—which precludes admission of evidence at trial if it was obtained in violation of the Fourth Amendment—‘is not a personal constitutional right.” Stone, 428 U.S. at 486. “It is not calculated to redress the injury to the privacy of the victim of the search or seizure” but rather to deter police misconduct. /d. (citation omitted). 4 Ground Three raises only a Fourth Amendment claim despite Petitioner's argument that the erroneous denial of the suppression motion also violated his Due Process rights under the Fourteenth Amendment. Hoffman v. Harris, No. 16-3994, 2017 WL 3951852, at *2 (6th Cir.

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Wood v. Warden Noble Correctional Institution, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wood-v-warden-noble-correctional-institution-ohsd-2025.