Morris v. Mitchell
Docket Number | 2:18-cv-1578-RDP |
Decision Date | 13 August 2024 |
Citation | Morris v. Mitchell, 2:18-cv-1578-RDP (N.D. Ala. Aug 13, 2024) |
Parties | ALFONSO MORRIS, AIS #0000Z695 Petitioner, v. PHILLIP MITCHELL, Warden of St. Clair[1]Correctional Facility, Respondent. |
Court | U.S. District Court — Northern District of Alabama |
R.DAVID PROCTOR CHIEF U.S. DISTRICT JUDGE
This matter is before the court on Alfonso Morris's Petition for Writ of Habeas Corpus By a Prisoner in State Custody Under Death Sentence.(Doc. # 1).SeeTitle 28U.S.C. § 2254.Morris was convicted of capital murder for the killing of Mariam Rochester and was sentenced to death.(Doc. # 1at 5).Here, this court sits in a habeas capacity under Title 28, U.S.C. § 2254 and considers Alfonso Morris's petition for federal relief from two Alabama capital convictions and a death sentence.Morris alleges that several guilt- and penalty-phase aspects of his capital trial for the robbery, burglary, and murder of Miriam Rochester violated his rights under the United States Constitution.
The Alabama courts have adjudicated most of Morris's federal claims within his petition.As a result, the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”)-which amended § 2254-demands deference to those state-court constitutional outcomes and constrains the scope of this court's review.Once AEDPA deference has attached to a constitutional claim, the standard for detaching it, while not insurmountable, is high.AEDPA draws a deferential line between objectively-wrong constitutional results and those outcomes in which the state courts' correctness is subject to fairminded disagreement.Adhering to that statutory balance, this court must rectify proven legal and factual errors of extreme constitutional malfunction in Morris's state-court capital proceedings.But this court must bear in mind the correct legal standard applicable here because AEDPA precludes substituting its judgment or otherwise reviewing de novo the decisions of Alabama courts.The question is this: Did they unreasonably reject Morris's arguments?
As the court explains below, many of Morris's adjudicated claims fall well within AEDPA's sizeable deferential range because the Alabama courts reached a reasonable result.For those closer calls-with few exceptions-no objective constitutional error occurred because fairminded jurists could defend the correctness of the state court decision.Thus, Morris lacks an AEDPA avenue to habeas relief on nearly all of his claims, which the Alabama courts addressed on the merits.As to those few adjudicated claims in which AEDPA deference is in doubt, the court concludes habeas relief is inappropriate either under de novo review or because the Alabama Criminal Court of Appeals(“ACCA”) did not address all the constitutional components of the asserted constitutional violation egregiously.And for various reasons, Morris cannot prevail on his remaining unadjudicated habeas allegations.
Before turning to Morris's habeas claims and Respondent's defenses, the court sets out a table of contents, shares some background about this capital case, and acknowledges several recurring standards of review under AEDPA.
I BACKGROUND…………………………………………………………………………9
II.HABEAS RE VIEW UNDER AEDPA………………………………………………...18
III.ANALYSIS…………………………………………………………………………………
1.State Court Proceedings……………………………………………………
2.The proper application of AEDPA deference precludes habeas relief on Morris's exhausted Biggers claim...........................................32
3.Morris's remaining allegations related to his identification claim do not entitle him to habeas relief..........................................................47
a. Exhaustion and procedural default……………………………47
b. Other deficiencies……………………………………………….52
1.State CourtProceedings..........................................................................53
2.Regardless of whether AEDPA deference applies, Morris has not established a constitutional violation related to his racial bias claim..........................................................................................................56
1.State Court Proceedings………………………………………………..63
2.Morris has not overcome AEDPA deference on any aspect of his Atkins claim……………………………………………………………..71 a. Morris has not developed a legal basis for relief under § 2254(d)(1)'s first clause…………………………………………71
b. Morris has not shown that the state courts decided his Atkins claim unreasonably under (d)(1) or (d)(2) ..................... 72
i. Intellectual Functioning Prong………………………...73
ii.Adaptive Functioning Prong…………………………...82
iii.Onset Prong……………………………………………..82
1.State Court Proceedings………………………………………………..98
2.AEDPA deference precludes habeas relief on Morris's unreliable DNA evidence claim…………………………………………………….99
1.State Court Proceedings………………………………………………107
2.Even if AEDPA deference is inapplicable because of an unreasonable factual determination, Morris has not proven that the state violated his Sixth Amendment right to a speedy trial ......... 110
3.Morris's remaining allegations do not support habeas relief………120
1.State Court Proceedings ........................................................................ 122
2.Morris has not satisfied his AEDPA deferential burden on his incompetency claim ................................................................................ 125
1.State Court Proceedings ........................................................................ 131
2.Even if AEDPA deference is inapplicable because of a contrary application of Supreme Court precedent, Morris has not proven that the trial court's limited interruptions violated his constitutional rights ............................................................................... 132
1.State Court Proceedings ........................................................................ 138
2.Morris has not overcome AEDPA deference on his due process challenge of the victim impact evidence under the Fourteenth Amendment ............................................................................................ 140
1.State Court Proceedings ........................................................................ 146
2.Morris has not met his AEDPA burden on his improper prosecutorial comments claim .............................................................. 148
3.Morris's remaining allegations do not support habeas relief ............ 156
1.State Court Proceedings ........................................................................ 157
2.Morris has not overcome AEDPA deference on his claim that the trial court mischarged the jury on reasonable doubt ......................... 160
3.Morris's remaining allegations do not support habeas relief ............ 171
1.State Court Proceedings ........................................................................ 172
2.Morris has not overcome AEDPA deference on his claim that the trial court incorrectly charged the jury on the sentencing factors....174
a. Morris has not overcome AEDPA deference on his unanimity requirement claim ................................................... 175
b. Morris has not overcome AEDPA deference on his for unanimity mitigating circumstances claim .............................. 177
c. Morris has not overcome AEDPA deference on his outweighing claim ...................................................................... 181
1.State Court Proceedings...
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