Stafford v. Davids
Docket Number | 2:20-cv-11136 |
Decision Date | 30 August 2023 |
Parties | LAWRENCE STAFFORD, Petitioner, v. JOHN DAVIDS, Respondent. |
Court | U.S. District Court — Eastern District of Michigan |
Petitioner Lawrence Stafford, a Michigan state prisoner confined at the Ionia Correctional Facility in Ionia, Michigan, filed a pro se petition for writ of habeas corpus under 28 U.S.C. § 2254. Petitioner is challenging his convictions by a Wayne County Circuit Court jury on charges of second-degree murder and felony firearm, for which he is serving prison terms of thirty to sixty years and two years respectively.
Now having reviewed the petition, Respondent's answer, and the Rule 5 materials, the Court concludes that the Michigan appellate courts were not unreasonable in affirming Petitioner's convictions. The petition will be dismissed.
I. Background
The Michigan Court of Appeals summarized the facts of Petitioner's case as follows:
People v. Stafford, No. 336842, 2018 WL 4577192, at *1 (Mich. Ct. App. Sept. 13, 2018).
Petitioner appealed his convictions as of right. His appointed appellate attorney argued that his conviction on the murder and weapons charges were not supported by sufficient evidence. Petitioner raised three additional issues pro se,[1]arguing (1), he was denied a fair trial because the prosecutor committed fraud upon the court; (2), he was denied due process when the prosecution knowingly presented the testimony of witness who had been tampered with; and (3), he was denied a fair trial and due process when the prosecutor knowingly presented false testimony.
The Michigan Court of Appeals affirmed Petitioner's convictions. Stafford, 2018 WL 4577192. Petitioner applied to the Michigan Supreme Court for leave to appeal, but it denied leave in a standard form order (because it was “not persuaded that the questions presented should be reviewed by this Court.”). People v. Stafford, 504 Mich. 944, 931 N.W.2d 353 (2019).
Petitioner filed a timely petition for a writ of habeas corpus. He raises the same four issues he argued in the state appellate courts, which are as follows:
I. The conviction must be reversed where the substantive evidence of record was not legally sufficient to prove beyond a reasonable doubt that Mr. Stafford - as principal or aider and abettor - committed the murder and firearm offenses.
II. Petitioner was denied a fair trial where the prosecutor committed fraud upon the court.
III. Petitioner was denied due process when the prosecution knowingly presented the testimony of Charles Deen with whom it knew the victim's sister had tampered and bribed to provide his testimony.
IV. Petitioner was denied his state and federal constitutional rights to a fair trial and due process where the prosecution knowingly presented false testimony through the testimony of Charles Deen, their chief witness, in order to secure a conviction.
Title 28 U.S.C. § 2254(d), as amended by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), Pub. L. No. 104-132, 110 Stat. 1214, imposes the following standard of review for habeas cases:
“A state court's decision is ‘contrary to' . . . clearly established law if it ‘applies a rule that contradicts the governing law set forth in [Supreme Court cases]' or if it ‘confronts a set of facts that are materially indistinguishable from a decision of Court and nevertheless arrives at a result different from [that] precedent.'” Mitchell v. Esparza, 540 U.S. 12, 15-16 (2003) (per curiam) (quoting Williams v. Taylor, 529 U.S. 362, 405-06 (2000)); see also Bell v. Cone, 535 U.S. 685, 694 (2002). “[T]he ‘unreasonable application' prong of § 2254(d)(1) permits a federal habeas court to ‘grant the writ if the state court identifies the correct governing legal principle from Court but unreasonably applies that principle to the facts of petitioner's case.'” Wiggins v. Smith, 539 U.S. 510, 520 (2003) (quoting Williams, 529 U.S. at 413); see also Bell, 535 U.S. at 694. However, Wiggins, 539 U.S. at 520-21 (citations omitted); see also Williams, 529 U.S. at 409.
The AEDPA “imposes a highly deferential standard for evaluating statecourt rulings . . . and demands that state-court decisions be given the benefit of the doubt.” Renico v. Lett, 559 U.S. 766, 773 (2010) (internal citation omitted). “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 (2011) (internal quotation and citation omitted). The Supreme Court has emphasized “that even a strong case for relief does not mean the state court's contrary conclusion was unreasonable.” Id. at 102. Pursuant to section 2254(d), “a habeas court must determine what arguments or theories supported or . . . could have supported, the state court's decision; and then it must ask whether it is possible fairminded jurists could disagree that those arguments or theories are inconsistent with the holding in a prior decision” of the Supreme Court. Id. Although section 2254(d), as amended by the AEDPA, does not completely bar federal courts from re-litigating claims that have previously been rejected in the state courts, a federal court may grant habeas relief only “in cases where there is no possibility fairminded jurists could disagree that the state court's decision conflicts with” the Supreme Court's precedents. Id. A “readiness to attribute error [to a state court] is inconsistent with the presumption that state courts know and follow the law.” Woodford v. Viscotti, 537 U.S. 19, 24 (2002).
Section 2254(d)(1) limits a federal habeas court's review to a determination of whether the state court's decision comports with clearly established federal law as determined by the Supreme Court at the time the state court renders its decision. Williams, 529 U.S. at 412; see also Knowles v. Mirzayance, 556 U.S. 111, 122 (2009) ( )(quoting Wright v. Van Patten, 552 U.S. 120, 125-26 (2008) (per curiam)); Lockyer v. Andrade, 538 U.S. 63, 71-72 (2003). Section 2254(d) “does not require a state court to give reasons before its decision can be deemed to have been ‘adjudicated on the merits.'” Harrington, 562 U.S. at 100. Furthermore, it “does not require citation of [Supreme Court] cases-indeed, it does not even require awareness of [Supreme Court] cases, so long as neither the reasoning nor the result of the state-court decision contradicts them.” Early v. Packer, 537 U.S. 3, 8 (2002)...
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