CAGER v. RIVELLO
2:22-cv-00316
W.D. Pa.Jun 6, 2025Background
- Jarod Cager filed a federal habeas corpus petition under 28 U.S.C. § 2254 challenging his 2014 conviction for first-degree murder and carrying a firearm without a license in Allegheny County, Pennsylvania.
- The petition alleged multiple grounds for relief, mostly claiming ineffective assistance of trial counsel, procedural errors, and evidentiary violations.
- The case was reviewed and recommended for denial by a magistrate judge, citing lack of merit in most claims and procedural default for several others.
- No objections to the magistrate judge’s Report and Recommendation (R&R) were filed by Cager.
- The district court reviewed the case for plain error and found none in the magistrate judge’s reasoning or recommendations.
- The court denied the habeas petition with prejudice and declined to issue a certificate of appealability, closing the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel (failure to investigate/call witness) | Counsel failed to present exculpatory testimony related to another suspect | State court properly applied federal law; no prejudice shown | Court found claims lacked merit or were procedurally defaulted |
| Ineffective assistance (failure to address jury/witness tampering) | Counsel failed to act on incidents of alleged tampering during trial | Claims not raised properly in state court, defaulted | Claims procedurally defaulted and not excused by cause |
| Brady violation (failure to disclose evidence) | Prosecution withheld exculpatory evidence regarding alternative suspect | No basis for relief, claim defaulted, no prejudice | Claim procedurally defaulted, no cause or prejudice shown |
| Trial court error (denial of discovery, charging decision) | Court improperly denied discovery; conviction was unlawful given charging | Proper rejection under state law; no showing of fundamental miscarriage of justice | Claims procedurally defaulted and not excused |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (prosecution must disclose exculpatory evidence)
- Slack v. McDaniel, 529 U.S. 473 (standard for granting a certificate of appealability)
- Coleman v. Thompson, 501 U.S. 722 (procedural default doctrine for federal habeas petitions)
- Martinez v. Ryan, 566 U.S. 1 (ineffective assistance during collateral proceedings may allow excusal of defaulted claims)