Cain v. Gidley
Decision Date | 19 July 2019 |
Docket Number | Case Number 15-10096 |
Parties | DARRYL CAIN, Petitioner, v. LORI GIDLEY, Respondent |
Court | U.S. District Court — Eastern District of Michigan |
Honorable David M. Lawson
Petitioner Darryl Cain stole a car at gunpoint from Courtney Spires in Detroit in 2010. For his efforts, he was convicted of carjacking and related crimes and sent to prison for at least 20 years. Following his unsuccessful appeals through the state courts, he filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254, alleging a variety of claims, 14 in all. None of the claims, however, supports issuance of the writ. The Court therefore will deny the petition.
The Michigan Court of Appeals summarized the facts of the case on direct appeal as follows:
People v. Cain, 299 Mich. App. 27, 33-35, 829 N.W.2d 37, 41-42 (2012).
The jury found Cain guilty of carjacking, Mich. Comp Laws § 750.529a; unlawfully driving away an automobile (UDAA), Mich. Comp Laws § 750.413; two counts of receiving and concealing stolen property, Mich. Comp Laws § 750.535(7); felon in possession of a firearm,Mich. Comp Laws § 750.224f; and possession of a firearm in the commission of a felony (felony firearm), Mich. Comp Laws § 750.227b.
The court of appeals affirmed the convictions. The Michigan Supreme Court vacated "that part of the Court of Appeals opinion stating that a 'completed larceny' is an element of unlawfully driving away a motor vehicle (UDAA)," affirmed Cain's convictions for carjacking and UDAA, and denied the application for leave to appeal in all other respects. People v. Cain, 495 Mich. 874, 838 N.W.2d 150 (2013). The Supreme Court denied Cain's petition for a writ of certiorari. Cain v. Michigan, 572 U.S. 1069 (2014).
Cain then filed a petition for writ of habeas corpus, which was held in abeyance so that he could return to the state courts to exhaust additional claims. Cain's post-conviction motion for relief from judgment was denied, People v. Cain, No. 10-006812-01-FC , and the Michigan appellate courts denied the petitioner leave to appeal. People v. Cain, No. 329210 (Mich. Ct. App. Nov. 13, 2015); lv. den. 500 Mich. 864, 885 N.W.2d 294 (2016). Cain then returned to this Court, the stay was lifted, and Cain filed an amended petition, which raises the following claims:
Amend. Pet. at 5-13, ECF No. 11, PageID.67-75.
The warden filed an answer to the petition arguing that some of the claims are subject to the defense of procedural default. The "procedural default" argument is a reference to the rule that the petitioner did not preserve properly some of his claims in state court, and the state court's ruling on that basis is an adequate and independent ground for the denial of relief. Coleman v. Thompson, 501 U.S. 722, 750 (1991). The Court finds it unnecessary to address this procedural question. It is not a jurisdictional bar to review of the merits, Howard v. Bouchard, 405 F.3d 459, 476 (6th Cir. 2005), and "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) (citing Lambrix v. Singletary, 520 U.S. 518, 525 (1997)). The procedural defense will not affect the outcome of this case, and it is more efficient to proceed directly to the merits.
Certain provisions of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), Pub. L. No. 104-132, 110 Stat. 1214 (Apr. 24, 1996), which govern this case, "circumscribe[d]" the standard of review federal courts must apply when considering an application for a writ of habeas corpus raising constitutional claims. See Wiggins v. Smith, 539 U.S. 510, 520 (2003). A federal court may grant relief only if the state court's adjudication "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States," or if the adjudication "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." 28 U.S.C. § 2254(d)(1)-(2).
"Clearly established Federal law for purposes of § 2254(d)(1) includes only the holdings, as opposed to the dicta, of Court's decisions." White v. Woodall, 572 U.S. 415, 419(2014) (quotation marks and citations omitted). "As a condition for obtaining habeas corpus from a federal court, a state prisoner must show that the state court's ruling on the claim being presented in federal court was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement." Harrington v. Richter, 562 U.S. 86, 103, (2011). The distinction between mere error and an objectively unreasonable application of Supreme Court precedent creates a substantially higher threshold for obtaining relief than de novo review. Mere error by the state court will not justify issuance of the writ; rather, the state court's application of federal law "must have been objectively unreasonable." Wiggins, 539 U.S. at 520-21 (quoting Williams v. Taylor, 529 U.S. 362, 409 (2000) (quotation marks omitted)). The AEDPA imposes a highly deferential standard for evaluating state-court rulings and demands that state-court decisions be "given the benefit of the doubt." Renico v. Lett, 559 U.S. 766, 773 (2010). Moreover, habeas review is "limited to the record that was before the state court." Cullen v. Pinholster, 563 U.S. 170, 180 (2011).
The claims Cain raised in his post-conviction motion were not decided by the state appellate courts with reasoned opinions; instead they were rendered in summary orders. Nonetheless, the deference required by the AEDPA still must be afforded. "Under [Harrington v. Richter], '[w]hen a federal claim has...
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