Douglas Mathis v. Roland Colson
528 F. App'x 470
6th Cir.2013Background
- Mathis shot and killed Selwyn Ward at a Tennessee campsite; Ward was unarmed.
- Petitioner and brother Jeff Mathis drove up to Ward’s camp, leading to a fatal confrontation.
- Mathis pleaded guilty to second-degree murder; the court later vacated that conviction and retried him as first-degree premeditated murder, resulting in life imprisonment.
- Direct appeal challenged sufficiency of evidence, jury instructions, and alleged prosecutorial and evidentiary errors.
- Post-conviction and state habeas petitions followed; federal habeas petition was filed years later and is the subject of this appeal.
- District court denied relief; petitioner appeals on five grounds, including double jeopardy/due process and ineffective assistance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of federal claims | Mathis fairly presented federal issues in state courts. | State court procedures and grounds barred review. | Procedural exhaustion/default barred federal review. |
| Double jeopardy and due process after vacatur | Trial after vacatur violated double jeopardy and due process. | No federal issue properly exhausted; claims defaulted. | Claim procedurally defaulted; denied on exhaustion grounds. |
| Prosecutorial comments and fair trial | Prosecutor comments violated fair trial rights; not adequately waived. | Waiver/default rule bars review; any error was harmless. | Procedural default barred review; no reversal on merits. |
| Sufficiency of the evidence for premeditation | Evidence failed to show premeditation beyond a reasonable doubt. | Evidence supported premeditation; reasonable juror could find it. | Evidence supported premeditation; state court not unreasonable. |
| Impartial jury claim and curative instructions | Juror interactions and 'murder weapon' label deprived impartiality; juror bias possible. | Default bar applies; curative instruction cured potential error. | Procedural default; some claims abandoned; others resolved by harmless error standard. |
Key Cases Cited
- Williams v. Taylor, 529 U.S. 362 (2000) (guides deference for ‘unreasonable application’ of federal law)
- Beard v. Kindler, 558 U.S. 53 (2010) (exhaustion requirements and cause-and-prejudice analysis)
- O'Sullivan v. Boerckel, 526 U.S. 838 (1999) (fair presentation requirement in federal habeas petitions)
- Rose v. Lundy, 455 U.S. 509 (1982) (total exhaustion rule requires dismissal of unexhausted claims)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence)
- Francis v. Franklin, 471 U.S. 307 (1985) (fair trial standards presume jurors follow curative instructions)
- Bruton v. United States, 391 U.S. 123 (1968) (curative instructions and prejudice considerations)
- Seymour v. Walker, 224 F.3d 542 (2000) (plain-error review does not override procedural default)
- Beard v. Kindler, 558 U.S. 53 (2009) (adequacy of state-law procedural bars)