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Brooks v. Mahalley

United States District Court, E.D. Pennsylvania

August 16, 2019

STEVEN BROOKS, Petitioner,
v.
LAWRENCE MAHALLEY, et al., Respondents.

          MEMORANDUM

          GENE E.K. PRATTER UNITED STATES DISTRICT JUDGE

         Petitioner Steven Brooks seeks habeas corpus relief in challenging his state court convictions for robbery, criminal conspiracy, simple assault, and burglary. Mr. Brooks is serving a 15 to 30-year sentence. After the Report and Recommendation of Magistrate Judge David R. Strawbridge (the “R&R”) recommended denying Mr. Brooks' Petition, Mr. Brooks filed objections. As set forth below, Mr. Brooks' objections are overruled and the R&R is adopted in full.

         Legal Standard

         This Petition is governed by the Antiterrorism and Effective Death Penalty Act of 1996.

         1. Exhaustion

         Under AEDPA, a federal court may not grant a petition for habeas corpus unless the applicant has exhausted all available state court remedies. 28 U.S.C. § 2254(b)(1). The exhaustion requirement ensures that state courts are provided with the first opportunity to review federal constitutional challenges to state court convictions, thus preserving the role of state courts in protecting federally guaranteed rights. Rose v. Lundy, 455 U.S. 509, 515-19 (1982). To satisfy the exhaustion requirement, a petitioner must demonstrate that he has “fairly presented” all claims in the federal petition to the state courts, including the highest court in which the petitioner was entitled to review. O'Sullivan v. Boerckel, 526 U.S. 838, 848 (1999). The fair presentation requirement is met when a petitioner “present[s] a federal claim's factual and legal substance to the state courts in a manner that puts them on notice that a federal claim is being asserted.” McCandless v. Vaughn, 172 F.3d 255, 261 (3d Cir. 1999) (citations omitted).

         An unexhausted habeas claim becomes procedurally defaulted when the petitioner has no further state remedies. See Wenger v. Frank, 266 F.3d 218, 223 (3d Cir. 2001), cert. denied, 535 U.S. 957 (2002). Petitioners may pursue procedurally defaulted habeas claims in federal court in limited circumstances, however. See, e.g., Edwards v. Carpenter, 529 U.S. 446, 451 (2000) (courts may review an unexhausted habeas claim where there is “sufficient probability” that failure “will result in a fundamental miscarriage of justice.”). The Supreme Court identified one such exception in Martinez v. Ryan, 566 U.S. 1 (2012). Martinez states that a habeas petitioner's failure to exhaust a claim during state court collateral review is excused if (1) counsel's failure, during state court collateral review, satisfies the test for ineffective assistance of counsel identified in Strickland v. Washington, 466 U.S. 668 (1984), and (2) that failure was “substantial, ” i.e., has “some merit.” Martinez, 566 U.S. at 14.

         2. Substantive Review

         When a petitioner challenging his state court conviction brings a properly exhausted habeas claim (or a claim within an exception to the procedural default rule), § 2254(d) permits the federal court to grant a petition only if (1) the state court's adjudication of the claim “resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States, ” or (2) the adjudication “resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding.” 28 U.S.C. § 2254(d)(1)-(2); see Parker v. Matthews, 567 U.S. 37, 40-49 (2012) (overturning a Sixth Circuit decision granting habeas relief because the state court's decision denying relief was not objectively unreasonable); Garrus v. Sec'y Pennsylvania Dept. of Corr., 694 F.3d 394, 400 (3d Cir. 2012). “Under the ‘contrary to' clause, a federal habeas court may grant the writ 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 (2000).

         A state court decision involves an unreasonable application of Supreme Court precedent “if the state court identifies the correct governing legal rule from the Court's cases but unreasonably applies it to the facts of the particular state prisoner's case.” Williams, 529 U.S. at 407-08. For “a reviewing federal court to find a state court's application of Supreme Court precedent ‘unreasonable,' the state court decision must be more than incorrect or erroneous; it must have been objectively unreasonable.” Marshall v. Cathel, 428 F.3d 452, 462 (3d Cir. 2005) (quoting Wiggins v. Smith, 539 U.S. 510, 520 (2003)).

         Discussion

         Mr. Books' Petition raises various claims for ineffective assistance of counsel, all of which the R&R recommends denying. Mr. Brooks objects to the R&R on four grounds: (1) the R&R failed to grant Mr. Brooks an evidentiary hearing regarding his trial counsel's failure to object to evidence allegedly destroyed by the Commonwealth, (2) the R&R failed to account for unusual circumstances surrounding fingerprint evidence against Mr. Brooks, to which his trial counsel did not object, (3) the R&R failed to consider the potential exculpatory value of evidence allegedly destroyed by the Commonwealth and to which trial counsel did not object, and (4) the R&R failed to sua sponte determine that Mr. Brooks' ineffective assistance of counsel claims were not procedurally defaulted.

         The Court addresses each of Mr. Brooks' objections to the R&R in turn (grouping together objections one and three), but must first place the objections in context, as they interact with the necessary ineffective assistance of counsel analysis.[1] Mr. Brooks alleges in his Petition that trial counsel was ineffective for failing to raise several evidentiary objections; however, Mr. Brooks did not raise his ineffective assistance of counsel claims in his timely PCRA petition. Therefore, before the Court can address trial counsel's effectiveness or ineffectiveness, the Court must first determine whether Mr. Brooks' PCRA counsel was ineffective by failing to raise the claims regarding trial counsel's ineffectiveness. See Martinez, 566 U.S. at 14. The Court's ineffective assistance of counsel inquiries proceed in two steps. At step one, the Court assesses the actions of PCRA Counsel, determining whether PCRA counsel's alleged ineffectiveness is actionable. If the Court were to determine that PCRA counsel was ineffective, the inquiry would move to step two. At step two, the Court would asess the effectiveness of trial counsel. For each of Mr. Brooks' objections, the Court need not proceed past step one.

         1. Objections 1 and 3: Ineffective Assistance of Trial Counsel in Failing to ...


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