Hayes v. Horton
| Decision Date | 31 March 2022 |
| Docket Number | Case No. 1:19-cv-13470 |
| Citation | 596 F.Supp.3d 978 |
| Parties | Quandraiko HAYES, Petitioner, v. Connie HORTON, Respondent. |
| Court | U.S. District Court — Eastern District of Michigan |
Quandraiko Hayes, Kincheloe, MI, Pro Se.
Andrea M. Christensen-Brown, Jared D. Schultz, Michigan Department of Attorney General, Lansing, MI, for Respondent.
Petitioner Quandraiko Hayes was convicted by a judge in the Wayne County Circuit Court of assault with intent to do great bodily harm less than murder (AWIGBH), MICH. COMP LAWS § 750.84 ; intentionally discharging a firearm in a dwelling causing serious impairment of a body function, MICH. COMP LAWS § 750.234b(4) ; felony firearm, MICH. COMP LAWS § 750.227b ; and being a fourth felony habitual offender, MICH. COMP LAWS § 769.12. See ECF No. 1 at PageID.12.
Petitioner, incarcerated at the Kinross Correctional Facility in Kincheloe, Michigan, has filed a pro se application for a writ of habeas corpus under 28 U.S.C. § 2254. ECF No. 1. Petitioner contends (1) that there was insufficient evidence to convict him, (2) that he was denied the effective assistance of counsel, (3) that his sentence violated the Eighth Amendment because it was disproportionate, and (4) that the sentencing court violated the Ex Post Facto Clause by using his prior convictions to impose a mandatory minimum of 25 years’ imprisonment on the habitual-offender charge.
Respondent filed an answer to the Petition, asserting that Petitioner's claims lack merit, are procedurally defaulted, or both. ECF No. 10. This Court agrees that Petitioner's claims have no merit or are procedurally defaulted. Accordingly, the Petition will be denied.
Petitioner was convicted at a bench trial in the Wayne County Circuit Court. This Court recites the relevant facts upon which the Michigan Court of Appeals relied, which are presumed correct on habeas review under 28 U.S.C. § 2254(e)(1). See Wagner v. Smith , 581 F.3d 410, 413 (6th Cir. 2009) :
This case arises from the nonfatal shooting of the victim in the early morning hours of February 7, 2017. The prosecution presented testimony from the victim and his girlfriend. Both witnesses testified that they had been staying with Hayes at his home, but Hayes told them to leave and then retrieved a shotgun. Hayes fired the gun, hitting the victim in the arm. The victim, who the trial court found was reluctant to testify at trial, claimed that the shooting was an accident. The victim's girlfriend denied seeing the shot fired and said she was intoxicated at the time. Hayes testified on his own behalf and claimed that the shooting was accidental. The trial court discredited the testimony indicating that the shooting was accidental and found the testimony offered by the victim's girlfriend unreliable because she was intoxicated. It found beyond a reasonable doubt that Hayes intentionally fired the shotgun at the victim and convicted Hayes of AWIGBH, intentional discharge of a firearm in or at a dwelling causing serious impairment, and felony-firearm. Pursuant to MCL 769.12(1)(a), the trial court sentenced Hayes to mandatory 25-year minimum sentences for the AWIGBH and intentional discharge of a firearm convictions, to be served consecutive to a two-year sentence for the felony-firearm conviction. This appeal followed.
Petitioner seeks a writ of habeas corpus on the following grounds:
As amended by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. § 2254(d) imposes the following standard of review for habeas cases:
28 U.S.C. § 2254(d).
A decision of a state court is "contrary to" clearly established federal law if the state court arrives at a conclusion opposite to that reached by the Supreme Court on a question of law or if the state court decides a case differently than the Supreme Court has on a set of materially indistinguishable facts. Williams v. Taylor , 529 U.S. 362, 405–06, 120 S.Ct. 1495, 146 L.Ed.2d 389 (2000). An "unreasonable application" occurs when "a state court decision unreasonably applies the law of [the Supreme Court] to the facts of a prisoner's case." Id. at 409, 120 S.Ct. 1495. A federal habeas court may not "issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly." Id. at 410–11, 120 S.Ct. 1495. "[A] state court's determination that a claim lacks merit precludes federal habeas relief so long as ‘fairminded jurists could disagree’ on the correctness of the state court's decision." Harrington v. Richter , 562 U.S. 86, 101, 131 S.Ct. 770, 178 L.Ed.2d 624 (2011) (citing Yarborough v. Alvarado , 541 U.S. 652, 664, 124 S.Ct. 2140, 158 L.Ed.2d 938 (2004) ). In this way, to obtain habeas relief in federal court, state prisoners must show that the state court's rejection of their claim "was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement." Id. at 103, 131 S.Ct. 770.
Petitioner first contends that there was insufficient evidence presented at trial for the judge to convict him of the charges: to show that the shooting was intentional rather than accidental. ECF No. 1 at PageID.28–32.
It is beyond question that "the Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged." In re Winship , 397 U.S. 358, 364, 90 S.Ct. 1068, 25 L.Ed.2d 368 (1970).
But in reviewing the sufficiency of the evidence to support a criminal conviction, the crucial question is "whether the record evidence could reasonably support a finding of guilt beyond a reasonable doubt." Jackson v. Virginia , 443 U.S. 307, 318, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979) ; see also William E. Thro, No Angels in Academe: Ending the Constitutional Deference to Public Higher Education , 5 BELMONT L. REV. 27, 55 (2018) ().
The court need not "ask itself whether it believes that the evidence at the trial established guilt beyond a reasonable doubt." Id. Rather, the 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." Id. at 307, 99 S.Ct. 2781. The Jackson standard applies to bench trials, as well as to jury trials. See, e.g. , United States v. Bronzino , 598 F. 3d 276, 278 (6th Cir. 2010).
A federal habeas court cannot overturn a state-court decision that rejects a sufficiency of the evidence claim simply because the federal court disagrees with the state court's resolution of that claim. Rather, the federal court may grant habeas relief only if the state-court decision was an objectively unreasonable application of the Jackson standard. See Cavazos v. Smith , 565 U.S. 1, 2, 132 S.Ct. 2, 181 L.Ed.2d 311 (2011) (). Indeed, "the only question under Jackson is whether that finding was so insupportable as to fall below the threshold of bare rationality." Coleman v. Johnson , 566 U.S. 650, 656, 132 S.Ct. 2060, 182 L.Ed.2d 978 (2012).
A state court's determination that the evidence does not fall below that threshold is entitled...
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