Staten v. Davis, No. 17-99008 (9th Cir. 2020)
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The Ninth Circuit affirmed the district court's denial of a habeas corpus petition challenging petitioner's conviction and capital sentence for murdering his parents. Petitioner alleged that he received ineffective assistance of trial counsel because his lawyer failed to present additional evidence of third-party culpability. Petitioner also alleged that a contract for indigent defense services between Los Angeles County and the Pomona Contract Lawyers Association (PCLA) violated his constitutional rights because it interfered with his ability to obtain second trial counsel.
The panel held that trial counsel rendered deficient performance by failing to present testimony that gang members appeared to claim credit for the murders, but that counsel did not perform deficiently by failing to find and call a gang expert to counter the testimony of the prosecution's gang expert. In this case, fairminded jurists could disagree as to whether the testimony of five witnesses regarding the gang members' boasting was reasonably likely to have changed the outcome of petitioner's trial. Therefore, there were reasonable grounds for the California Supreme Court to conclude that the omitted testimony would not have altered the outcome. The panel also held that the California Supreme Court's summary denial on the merits of the PCLA contract claims (claims 1, 2, 3, and 11) was not unreasonable, because there is no evidence in the record that trial counsel was appointed to represent petitioner under the contract, was a member of the PCLA at the time the initial contract was signed, or was a signatory to the original contract.
Court Description: Habeas Corpus / Death Penalty. The panel affirmed the district court’s denial of Deondre Staten’s habeas corpus petition challenging his conviction and capital sentence for murdering his parents. Staten alleged that he received ineffective assistance of trial counsel because his lawyer failed to present additional evidence of third-party culpability. The panel held that Staten’s trial counsel rendered deficient performance by failing to present testimony that gang members appeared to claim credit for the murders, but that counsel did not perform deficiently by failing to find and call a gang expert to counter the testimony of the prosecution’s gang expert. The panel held that fairminded jurists could disagree as to whether the testimony of five witnesses regarding the gang members’ boasting was reasonably likely to have changed the outcome of Staten’s trial, and that the California Supreme Court’s summary denial of the ineffective-assistance claim was therefore not objectively unreasonable. Staten also brought claims that a contract for indigent defense services between Los Angeles County and the Pomona Contract Lawyers Association (PCLA) violated his constitutional rights because it interfered with his ability to obtain second trial counsel. The panel held that the California Supreme Court’s summary denial of these claims was reasonable because there is no evidence in the record that STATEN V. DAVIS 3 trial counsel was appointed to represent Staten pursuant to the contract, was a member of the PCLA at the time the initial contract was signed, or was a signatory to the original contract. Judge Berzon dissented from the majority’s holding that the California Supreme Court’s imputed holding as to whether trial counsel’s deficient performance likely prejudiced the outcome of Staten’s trial was a reasonable application of clearly established Supreme Court law. She would hold that there was prejudice under Strickland v. Washington, 466 U.S. 668 (1984), that any conclusion to the contrary was unreasonable, and that 28 U.S.C. § 2254(d) therefore does not preclude habeas relief. 4 STATEN V. DAVIS
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