Stahl v. Haynes
Decision Date | 08 February 2021 |
Docket Number | Case No. C20-486-TSZ-MAT |
Parties | COURTNEY JAMES STAHL, Petitioner, v. RON HAYNES, Respondent. |
Court | U.S. District Court — Western District of Washington |
Petitioner, a state prisoner who is currently confined at Stafford Creek Corrections Center in Aberdeen, Washington, seeks relief under 28 U.S.C. § 2254 from a 2016 King County Superior Court judgment and sentence. Dkt. 4. Respondent has filed an answer to petitioner's habeas petition and submitted relevant portions of the state court record. Dkts. 9, 10. Petitioner has filed a response to respondent's answer. Dkts. 24, 25.
Having considered the parties' submissions, the balance of the record, and the governing law, the Court recommends that the federal habeas petition (Dkt. 4) be DENIED without an evidentiary hearing. The Court also recommends that a certificate of appealability be DENIED.
The Washington State Court of Appeals ("Court of Appeals"), on direct appeal, summarized the facts relevant to petitioner's conviction as follows:
Dkt. 10, Ex. 21, at 1-2; State v. Stahl, 199 Wash. App. 1014 (2017).
Petitioner appealed his convictions to the Court of Appeals filing both an opening brief through appellate counsel as well as a pro se statement of additional grounds. Dkt. 10, Exs. 18, 19. On June 5, 2017, the Court of Appeals affirmed the conviction. Dkt. 10, Ex. 21. Petitioner filed a petition for review through appellate counsel with the Washington Supreme Court ("Supreme Court"). Dkt. 10, Ex. 22. On November 8, 2017, the Supreme Court denied review without comment. Dkt. 10, Ex. 23. The Court of Appeals issued its mandate on January 12, 2018. Dkt. 10, Ex. 24.
On September 6, 2018, petitioner filed a pro se personal restraint petition (PRP) with the Court of Appeals. Dkt. 10, Exs. 25, 26. On March 22, 2019, the Court of Appeals dismissed the PRP. Dkt. 10, Ex. 29. Petitioner sought discretionary review in the Supreme Court. Dkt. 10, Ex. 30. The Commissioner of the Supreme Court denied review. Dkt. 10, Ex. 31. Petitioner filed a motion to modify the Commissioner's ruling. Dkt. 10, Ex. 32. The Supreme Court denied the motion to modify without comment. Dkt. 10, Ex. 33. The Court of Appeals issued a certificate of finality on February 28, 2020. Dkt. 10, Ex. 34. Petitioner timely filed this federal habeas petition on March 30, 2020. Dkts. 1, 4.
Petitioner identifies twelve grounds for habeas relief which are summarized as follows:
Respondent argues that petitioner failed to properly exhaust Grounds 1, 4, 10, 11, and 12, in the state courts and that those claims are now procedurally defaulted and cannot be presented in federal court. Dkt. 9. Respondent concedes that petitioner properly exhausted Grounds 2, 3, 5, 6, 7, 8, and 9, but argues that those claims should be denied on the merits. Id. Petitioner argues that all of his claims were properly exhausted and that the state courts' errors entitle him to relief. Dkts. 4, 23, 24. As discussed below, the Court concludes petitioner failed to properly exhaust Grounds 1, 4, 10, 11, and 12. These grounds are procedurally defaulted and should be denied. The Court further concludes that petitioner properly exhausted Grounds 2, 3, 5, 6, 7, 8, and 9, but that those claims should be denied on the merits. Likewise, petitioner's request for an evidentiary hearing should be denied.
Before seeking federal habeas relief, a state prisoner must exhaust the remedies available in the state courts. The exhaustion requirement reflects a policy of federal-state comity, intended to afford the state courts "an initial opportunity to pass upon and correct alleged violations of its prisoners' federal rights." Picard v. Connor, 404 U.S. 270, 275 (1971) (internal quotation and citation marks omitted).
There are two avenues by which a petitioner may satisfy the exhaustion requirement. First, a petitioner may properly exhaust his state remedies by "fairly presenting" his claim in each appropriate state court, including the state supreme court with powers of discretionary review, thereby giving those courts the opportunity to act on his claim. Baldwin v. Reese, 541 U.S. 27, 29 (2004); Duncan v. Henry, 513 U.S. 364, 365-66 (1995). "It has to be clear from the petition filed at each level in the state court system that the petitioner is claiming the violation of the federal constitution that the petitioner subsequently claims in the federal habeas petition." Galvan v. Alaska Dep't of Corrections, 397 F.3d 1198, 1204 (9th Cir. 2005).
Second, a petitioner may technically exhaust his state remedies by demonstrating that his "claims are now procedurally barred under [state] law." Gray v. Netherland, 518 U.S. 152, 162-63 (1996) (quoting Castille v. Peoples, 489 U.S. 436, 351 (1989)); see also Smith v. Baldwin, 510 F.3d 1127, 1139 (9th Cir. 2007) (en banc). If the petitioner is procedurally barred from presenting his federal claims to the appropriate state court at the time of filing his federal habeas petition, the claims are deemed to be procedurally defaulted for purposes of federal habeas review. O'Sullivan v. Boerckel, 526 U.S. 838, 848 (1999). A habeas petitioner who has defaulted his federal claims in state court meets the technical requirements for exhaustion because "there are no...
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