Matthews v. Lumpkin
Decision Date | 26 October 2020 |
Docket Number | No. 3:19-CV-0192,3:19-CV-0192 |
Parties | RYAN ANTONIO MATTHEWS, PETITIONER, v. BOBBY LUMPKIN, RESPONDENT. |
Court | U.S. District Court — Southern District of Texas |
The petitioner, Ryan Antonio Matthews, seeks a writ of habeas corpus under 28 U.S.C. § 2254 to challenge the conviction and sentence he received in state court in Brazoria County (Dkts. 1, 2). The respondent, Bobby Lumpkin,1 has answered with a motion for summary judgment (Dkt. 15) arguing that Matthews is not entitled to relief. Matthews has filed a reply (Dkt. 28). After considering all the pleadings, the state-court records, and the applicable law, the court will grant the respondent's motion, deny the petition, and dismiss this action for the reasons explained below.
The victim, a sixteen-year-old Pearland high-school student, took a home pregnancy test on February 26th, 2014, that rendered positive results. A doctor's visit confirmed that she was twelve weeks pregnant. The victim was excited a week later to find that she carried twins. She decided to transfer to an alternative school in Pearland.
On March 21, the last school day before the victim's transfer, family members came home to find the house in disarray. There was no sign of forced entry. The victim's father eventually found her dead, lying in a pool of blood. She had died from a combination of manual strangulation and stab wounds to her neck and head.
The police investigation quickly turned to the victim's sexual partner, sixteen-year-old Ryan Antonio Matthews. Matthews had been in a casual sexual relationship with the victim for several months but still maintained relationships with other girls. Matthews did not share the victim's enthusiasm about the pregnancy; he saw it as an impediment to his dreams of college education and sports stardom. Matthews had repeatedly and persistently urged the victim to abort the pregnancy, either through a medical provider or through self-harm.
Matthews was the last person known to have been with the victim. A friend had dropped Matthews off at the victim's home only a few hours before her familyfound her dead. Testing confirmed that Matthews had sexual relations with the victim soon before her death. When questioned by police, Matthews repeatedly lied about various material facts. The police arrested Matthews for the murder of the victim and their two unborn children.
In Texas, a juvenile court has original jurisdiction over any child under seventeen years of age. See Tex. Fam. Code §§ 51.02(2), 51.04. Matthews was only a few weeks shy of his seventeenth birthday when the offense occurred.2 The State of Texas initially filed charges in the County Court at Law No. 2 and Probate Court of Brazoria County, sitting as a juvenile court. In the matter of Ryan Antonio Matthews, No. JV 19869H. On May 23, 2014, the Brazoria County prosecuting attorney filed a petition for a discretionary transfer to criminal court alleging that a child, Matthews, had committed two counts of capital murder.
Under Texas law, "[t]he juvenile court may waive its exclusive original jurisdiction and transfer a child to the appropriate district court or criminal district court for criminal proceedings" if certain conditions are met. Tex. Fam. Code § 54.02. As part of the transfer proceedings, Dr. Michael Fuller, a forensic psychiatrist with the University of Texas Medical Branch, examined Matthews on June 5, 2014. Dr. Fuller was one of four witnesses who testified in a July 8, 2014, juvenile-court hearing on the transfer petition. Dr. Fuller explained that Matthewsdid not have a history of major psychiatric illness, was not intellectually disabled, and exhibited no impairment in his memory, judgment, reasoning, or insight. Dr. Fuller testified that Matthews understood the charges against him and possessed a rational ability to engage in a reasoned choice of legal strategies and options—including the ability to enter a plea and testify at trial.
The juvenile court also received evidence of Matthews's prior offenses, (assault and credit-card abuse), his poor school disciplinary history, and his participation in an altercation while in custody. A police officer testified about Matthews's dishonesty during the investigation, his threats to other students who asked about the pregnancy, and his flight risk.
After considering the parties' testimony, evidence, and argument, the juvenile court waived its jurisdiction and transferred the case to the state district court. The juvenile court entered an order outlining the reasons for certifying Matthews for prosecution as an adult: (1) he exhibited sufficient sophistication and maturity to stand trial in adult court; (2) he possessed sufficient sophistication and maturity to aid an attorney in his defense; and (3) the nature of the offense and Matthews's criminal history weighed in factor of protecting the public through adult certification, especially given the paucity of evidence showing the hope for rehabilitation through juvenile procedures. The juvenile court's order also made case-specific findings of fact based on the nature of the offense, Matthews's threats to others, and his age which had nearly removed him from juvenile court's originaljurisdiction.
On July 24, 2014, Matthews was indicted for two counts of capital murder in Cause 73841, filed in the 239th District Court for Brazoria County. Trial began on April 14, 2015. As set forth by the state intermediate appellate court, the trial evidence established the following facts:
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