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Stegall v. Bauman

United States District Court, E.D. Michigan, Southern Division

July 11, 2018

RALPH STEGALL, Petitioner,



         Petitioner Ralph Stegall was convicted by a Wayne County, Michigan jury of kidnapping and first-degree criminal sexual conduct, and he was sentenced to prison terms of at least 29 years. After his state appellate and post-judgment proceedings yielded him no relief, he filed the present pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254. He has raised several challenges to the validity of his convictions and sentences, but because none has merit, the Court will deny the petition.


         The Michigan Court of Appeals summarized the basic facts of the case as follows:

Defendant's convictions stem from his protracted assault of the victim. Defendant kidnapped the victim at gunpoint and drove her to a house. With the assistance of a woman present in the home, defendant proceeded to sexually assault the victim for approximately 4-1/2 hours. Defendant eventually instructed the victim to clean herself in the bathroom; the victim pretended to do so and put on her clothes. Although defendant offered to drop the victim off somewhere, she fled when he went to the driver's side door of his truck.

People v. Stegall, No. 288703, 2010 WL 395751, at *1 (Mich. Ct. App. Feb. 4, 2010).

         The state prosecutor charged the petitioner with one count each of kidnapping and armed robbery, and six counts of first-degree criminal sexual conduct, even though there were only two discrete acts of sexual penetration. The State contended that each act of penetration supported three ways of violating the criminal statute. The jury convicted the petitioner of kidnapping and all six counts, and he was sentenced to concurrent prison terms of 29 to 50.

         On direct appeal, the court of appeals vacated four of the criminal conduct convictions, on the ground that convicting the petitioner six times under three alternate theories for two counts of sexual penetration violated the Double Jeopardy Clause. Stegall, 2010 WL 395751, at *2-3. Otherwise, the convictions and sentences were affirmed. Ibid. The Michigan Supreme Court denied leave to appeal. People v. Stegall, 486 Mich. 1048, 783 N.W.2d 366 (2010) (table).

         The petitioner filed a petition for writ of habeas corpus, which was held in abeyance so that the petitioner could return to the state courts to exhaust additional claims. He filed a post-conviction motion for relief from judgment in the trial court, which was denied. He then filed a motion for reconsideration and “articulation, ” which the judge construed as a successive motion for relief from judgment and denied under Michigan Court Rule 6.502(G), which bars filing successive motions for relief from judgment in the absence of newly discovered evidence or a retroactive change in the law. People v. Stegall, No. 08-008387-01 (Third Jud. Cir. Ct. Aug. 2, 2013).

         The Michigan appellate courts denied the petitioner leave to appeal from the denial of his post-conviction motions. People v. Stegall, No. 318249 (Mich. Ct. App. Mar. 17, 2014); lv. den. 497 Mich. 902, 856 N.W.2d 14 (2014) (table); recon. den. 497 Mich. 985, 861 N.W.2d 18 (2015) (table). The petitioner filed another post-conviction motion for relief from judgment, which was denied. People v. Stegall, No. 08-008387-01 (Third Jud. Cir. Ct. Mar. 25, 2015).

         On June 9, 2015, this Court reopened the case, denied the petitioner's motion for another stay, and permitted him to file an amended habeas petition. In his original (claims I through III) and amended (claims IV through VII) habeas petitions, the petitioner seeks relief on the following grounds:

I. Abuse of discretion. The trial court reversibly erred in overruling a timely defense objection to Sergeant Decker being allowed to state his personal opinion to the jury that appellant lied about the cause of his injury.
II. Violation of the protection against double jeopardy.
III. Legal sufficiency of the evidence.
IV. Whether the Court of Appeals' ruling of Sgt. Decker's hearsay opinion testimony assisted the jury in determining a fact in issue, that [Stegall] had a gun in the time frame [the victim] alleged she was kidnapped and assaulted was unreasonable and rose to the level of a constitutional violation.
V. [Stegall] did not receive the effective assistance of trial counsel when counsel chose a defense supported by minimal quality of evidence while ignoring a defense that could have been supported by a substantial amount of evidence.
VI. Whether the trial court erred by admitting evidence of prior bad acts, and whether the prosecutor abused her discretion in overcharging petitioner in violation of the Fourteenth and Fifteenth Amendments.
VII. Whether [the] trial court abused its discretion by denying [Stegall's] motions for relief from judgment, and ruling that [Stegall's] separate motions were successive motions under MCR 6.502(G).

Pet. at 4, 6, 7; amend. pet. at 1, 3, 13, 15.

         The respondent filed an answer to the petition raising the defenses of procedural default and untimeliness. The “procedural default” argument is a reference to the rule that the petitioner did not preserve properly some of his claims in state court, and the state court's ruling on that basis is an adequate and independent ground for the denial of relief. Coleman v. Thompson, 501 U.S. 722, 750 (1991). The untimeliness argument references the requirement that a habeas petitioner must bring his claims within one year of the date his conviction becomes final. See 28 U.S.C. 2244(d)(1). In this case, although the petition was stayed in this Court, the petitioner was late with his post- conviction motion filing in state court after the stay was issued. The Court finds it unnecessary to address these procedural questions. They are not a jurisdictional bar to review of the merits, Howard v. Bouchard, 405 F.3d 459, 476 (6th Cir. 2005) (procedural default); Smith v. State of Ohio Dept. of Rehabilitation, 463 F.3d 426, 429, n.2 (6th Cir. 2006) (statute of limitations), and “federal courts are not required to address a procedural-default issue before deciding against the petitioner on the merits, ” Hudson v. Jones, 351 F.3d 212, 215 (6th Cir. 2003) (citing Lambrix v. Singletary, 520 U.S. 518, 525 (1997)). These procedural defenses will not affect the outcome of this case, and it is more efficient to proceed directly to the merits.


         The provisions of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), Pub. L. No. 104-132, 110 Stat. 1214 (Apr. 24, 1996), which govern this case, “circumscribe[d]” the standard of review federal courts must apply when considering an application for a writ of habeas corpus raising constitutional claims, including claims of ineffective assistance of counsel. See Wiggins v. Smith, 539 U.S. 510, 520 (2003). Because Stegall filed his petition after the AEDPA's effective date, its standard of review applies. Under that statute, if a claim was adjudicated on the merits in state court, a federal court may grant relief only if the state court's adjudication “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 if 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). “Clearly established Federal law for purposes of § 2254(d)(1) includes only the holdings, as opposed to the dicta, of [the Supreme] Court's decisions.” White v. Woodall, 572 U.S. 415, ---, 134 S.Ct. 1697, 1702 (2014) (internal quotation marks and citations omitted). “As a condition for obtaining habeas corpus from a federal court, a state prisoner must show that the state court's ruling on the claim being presented in federal court was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement.” Harrington v. Richter, 562 U.S. 86, 103 (2011).

         The distinction between mere error and an objectively unreasonable application of Supreme Court precedent creates a substantially higher threshold for obtaining relief than de novo review. The AEDPA thus imposes a highly deferential standard for evaluating state-court rulings, and demands that state-court decisions be “given the benefit of the doubt.” Renico v. Lett, 559 U.S. 766, 773 (2010) (finding that the state court's rapid declaration of a mistrial on grounds of jury deadlock was not unreasonable even where “the jury only deliberated for four hours, its notes were arguably ambiguous, the trial judge's initial question to the foreperson was imprecise, and the judge neither asked for elaboration of the foreperson's answers nor took any other measures to confirm the foreperson's prediction that a unanimous verdict would not be reached” (internal quotation marks and citations omitted)); see also Leonard v. Warden, Ohio State Penitentiary, 846 F.3d 832, 841 (6th Cir. 2017); Dewald v. Wriggelsworth, 748 F.3d 295, 298-99 (6th Cir. 2014); Bray v. Andrews, 640 F.3d 731, 737-39 (6th Cir. 2011); Phillips v. Bradshaw, ...

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