Goodson v. Dowling, 700 F. App'x 821

In 2012 Goodson entered a blind guilty plea to violating a child custody order and was sentenced to 35 years. He unsuccessfully sought to withdraw the plea.
The OCCA denied direct appeal; Goodson pursued state post-conviction relief arguing ineffective assistance of counsel among other claims. The trial court initially failed to certify its post-conviction denial, creating appellate-timing issues and leading to dismissal of one state appeal.
Goodson filed a § 2254 petition in federal court (Sept. 2015). The magistrate judge recommended dismissal as untimely or for Rule 2(c) defects; the district court found Goodson entitled to statutory and equitable tolling and ordered further proceedings.
Goodson’s amended § 2254 raised claims that his plea was not knowing/voluntary; trial and appellate counsel were ineffective; denial of self‑representation; venue and recusal denials; denial of evidentiary hearing; cumulative error; and excessive sentence.
The district court adopted the magistrate judge’s second R&R and denied relief: it found the OCCA reasonably concluded the plea was knowing and voluntary, rejected the ineffectiveness claims on the merits, found no clear assertion of self-representation, and held remaining claims meritless or waived by the plea.
Goodson sought a certificate of appealability (COA); the Tenth Circuit denied the COA, denied IFP, and dismissed the appeal, concluding reasonable jurists could not debate the district court’s conclusions.

Issue	Goodson's Argument	Dowling's Argument	Held
1. Whether plea was knowing, intelligent, and voluntary	Plea was involuntary and not knowing	State courts reasonably found plea was knowing and voluntary	Denied — OCCA’s decision reasonable under AEDPA
2. Whether trial counsel was ineffective	Counsel provided constitutionally deficient assistance	OCCA reasonably rejected ineffectiveness claims on the merits	Denied — no unreasonable application of federal law
3. Denial of right to self-representation	He clearly and unequivocally sought to represent himself	He never made a clear, unequivocal assertion of the right	Denied — no clear invocation of Faretta right
4. Trial court venue/recusal and denial of evidentiary hearing	Trial court erred in refusing transfer/recusal and hearing on affirmative defense	Denial did not violate due process; affirmative defenses waived by plea	Denied — claims meritless or waived
5. Appellate counsel ineffective for not raising issues	Appellate counsel omitted meritorious issues	Issues lacked merit, so no prejudice	Denied — no ineffective-assistance on appeal
6. Cumulative error	Multiple errors together warrant relief	No individual constitutional errors to accumulate	Denied — cumulative-error doctrine inapplicable
7. Sentence excessive	Sentence disproportionate/excessive	Sentence within statutory maximum and lawful	Denied — within statutory authority

Slack v. McDaniel, 529 U.S. 473 (2000) (COA standard for appealing habeas denials)
Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA "contrary to" and "unreasonable application" standards)
Cullen v. Pinholster, 563 U.S. 170 (2011) (review under § 2254 limited to the state-court record)
Littlejohn v. Trammell, 704 F.3d 817 (10th Cir. 2013) (standards for de novo review of unadjudicated federal claims)
Miles v. Dorsey, 61 F.3d 1459 (10th Cir. 1995) (burden to prove unadjudicated federal claims by a preponderance)