Ayala v. Chappell, No. 13-99005 (9th Cir. 2016)
Annotate this CasePetitioner, convicted of triple homicide and sentenced to death, appealed the district court's denial of his petition for habeas relief under 28 U.S.C. 2254. The court concluded that the procedural bar doctrine does not prevent the court from reaching the merits of petitioner's claims; the state court's conclusion that defense counsel was not constitutionally ineffective by failing to call into question the credibility of key prosecution witnesses was a reasonable application of Strickland v. Washington; the state court's summary denial of petitioner's Brady v. Maryland claims was not unreasonable where petitioner failed to establish that the State suppressed the information that underpins his certified Brady claims; the state court's denial of petitioner's witness intimidation claim was not contrary to or an unreasonable application of Webb v. Texas; the state court did not misapply federal law by rejecting petitioner's Napue v. Illinois claim; and the court rejected petitioner's other claims of error regarding the trial court's refusal to strike a juror for cause, exclusion of deceased witness's statements, prosecutorial misconduct during closing arguments, and penalty phase admission of a prior murder. Finally, the court rejected petitioner's claim of cumulative error and actual innocence. Accordingly, the court affirmed the judgment.
Court Description: Habeas Corpus / Death Penalty. The panel affirmed the district court’s denial of California state prisoner Reynaldo Medrano Ayala’s 28 U.S.C. § 2254 habeas corpus petition challenging his conviction and death sentence for triple homicide. Ayala argued that his defense team was constitutionally ineffective because his lawyers failed to present evidence that would have called into question the credibility of two key prosecution witnesses. The panel agreed with the district court that the California Supreme Court reasonably deferred to defense counsel’s choices regarding exclusion of gang affiliation evidence. The panel held that defense counsel’s initial decision not to present an inmate’s testimony to impeach prosecution witness Juan Manuel Meza did not fall below an objective standard of reasonableness. The panel also agreed with the district court’s analysis of counsel’s decision not to reopen the defense case after witness Rafael Mendoza Lopez (“Rafa”) recanted his exonerating testimony. The panel explained that in light of the risks and difficulties presented by pivoting away from a “no-gang” strategy, the decision not to make such a dramatic transition did not fall below an objectively reasonable standard of care. The panel held that the California Supreme Court likewise did not unreasonably deny Ayala’s ineffective-assistance claims as they relate to calling “other witnesses,” whom Ayala admitted counsel believed were gang-affiliated. The panel held that AYALA V. CHAPPELL 3 the California Supreme Court reasonably rejected Ayala’s claim that counsel failed to independently investigate the gang affiliation of numerous witnesses before deciding not to call them. The panel explained that even if it reviewed this claim de novo, Ayala would not be eligible for relief. Agreeing with the district court that evidence Ayala first presented in the federal proceedings does not strengthen his ineffective-assistance claims, the panel declined to stay his federal case so that he can seek reconsideration of those claims in the California Supreme Court. The panel held that it was not unreasonable for the California Supreme Court to resolve his ineffective-assistance claims without first granting him an evidentiary hearing. The panel denied on the merits an uncertified and unexhausted claim under Brady v. Maryland that the state failed to disclose impeachment evidence about Meza, and denied as moot Ayala’s request for a certificate of appealability as to that claim. Because Ayala did not establish that the state suppressed the information that underpins his certified Brady claims relating to Meza, the panel held that the state court’s summary denial of them was not unreasonable. The panel held that the California Supreme Court’s application of Brady, in summarily denying Ayala’s claim that the state concealed evidence that Detective Carlos Chacon had a longstanding bias against Ayala and his brother, was reasonable. The panel held that the California Supreme Court’s rejection of Ayala’s witness intimidation claim – that Rafa recanted his exonerating testimony as a result of threats and intimidation by Detective Chacon – was not contrary to or an unreasonable application of Webb v. Texas. The panel held that the California Supreme Court did not misapply federal 4 AYALA V. CHAPPELL law when it rejected Ayala’s claim that the state violated Napue v. Illinois by failing to correct Rafa’s testimony that Detective Chacon did not threaten him. The panel held that the California Supreme Court’s rejection of Ayala’s claim that the trial court committed constitutional error when it refused to strike a juror for cause was not contrary to or an unreasonable application of Morgan v. Illinois. The panel could not say that the California Supreme Court’s denial of Ayala’s claim that the trial court violated his constitutional right to present a defense when it excluded under California hearsay rules the exculpatory statements of a deceased witness was an unreasonable application of Chambers v. Mississippi. The panel held that the California Supreme Court’s rejection of Ayala’s claim of prosecutorial misconduct during closing argument was not an unreasonable application of Darden v. Wainwright, and that the rejection of Ayala’s related ineffective-assistance claim was likewise not unreasonable. The panel held that Ayala’s inability to show prejudice is fatal to his due-process challenge to the penalty-phase admission of evidence that nearly ten years before trial Ayala murdered a fellow inmate. The panel held that Ayala has not suffered the prejudice that would rise to the level of a constitutional violation based on cumulative error. The panel held that Ayala does not meet the high threshold of proof that would be required to support a freestanding claim, if cognizable on federal habeas review, of actual innocence. AYALA V. CHAPPELL 5
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