(HC) Fields v. California Department of Corrections
1:18-cv-01545
E.D. Cal.Jun 5, 2020Background
- In 2011 Fields assaulted a cohabitant (knife threats, severe battery) leaving the victim blind in one eye; he was charged with mayhem, assault with a deadly weapon, criminal threats, battery with serious bodily injury, corporal injury on a cohabitant, and vandalism, and faced three‑strikes exposure.
- Multiple competency/forensic evaluations (seven doctors including Atascadero State Hospital) produced mixed findings: several experts diagnosed malingering, some diagnosed psychosis, but no expert reliably found drug‑induced psychosis at the time of the offenses.
- Fields pled no contest and admitted enhancements in December 2012; the trial court imposed an aggregate term of 21 years after denying a Romero motion to strike prior strikes and denying probation.
- Fields pursued appeals in state court (Court of Appeal rejected his claims) and then filed a federal habeas petition asserting: (1) ineffective assistance for failing to develop/present a drug‑induced psychosis defense; (2) plea was coerced by counsel; (3) sentencing abuse (Romero denial and resentencing); and (4) restitution reduction.
- The magistrate judge applied AEDPA deference to the state courts, rejected all federal claims on the merits (finding counsel’s performance reasonable and sentencing issues state‑law matters), denied the restitution motion, and recommended denying the petition and a certificate of appealability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance — failure to develop/present drug‑induced psychosis at sentencing | Fields: counsel did not fully investigate or present mitigating evidence that he suffered drug‑induced psychosis during the offenses. | Respondent: counsel raised substance/psychosis mitigation; record lacked evidence of drug‑induced psychosis and many experts found malingering, so counsel’s choices were reasonable. | Denied — counsel’s performance not constitutionally deficient; Court of Appeal reasonably applied Strickland/AEDPA. |
| Involuntary/coerced plea | Fields: counsel coerced him into a no‑contest plea, refused to enter a guilty by reason of insanity plea, and misled him about leniency. | Respondent: plea colloquy and counsel’s advice were within competence; petitioner testified plea was knowing and voluntary. | Denied — plea was knowing and voluntary; no Strickland error in counsel’s advice. |
| Sentencing — Romero motion and resentencing procedures | Fields: trial court abused discretion by not adequately considering mental‑health mitigation, refusing supplemental probation report, and imposing a harsher resentencing term. | Respondent: Romero and other sentencing rulings are matters of state law and within trial court discretion; Court of Appeal found no abuse. | Denied — claims challenge state‑law sentencing discretion and do not present a federal violation; no federal habeas relief. |
| Restitution reduction motion | Fields: trial court misapplied California law and failed to weigh factors, so restitution should be reduced to statutory minimum. | Respondent: restitution determination is a state‑law matter not cognizable on federal habeas. | Denied — federal habeas does not review state‑law restitution errors. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑part test for ineffective assistance of counsel)
- Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference; “fairminded jurist” standard)
- Williams v. Taylor, 529 U.S. 362 (2000) (§2254 standard: contrary or unreasonable application of Supreme Court precedent)
- Tollett v. Henderson, 411 U.S. 258 (1973) (limits collateral attack on pre‑plea constitutional claims after voluntary plea)
- Hill v. Lockhart, 474 U.S. 52 (1985) (Strickland analysis in plea context; prejudice standard for pleas)
- Brady v. United States, 397 U.S. 742 (1970) (voluntariness of plea in plea‑bargaining context)
- Estelle v. McGuire, 502 U.S. 62 (1991) (federal habeas does not lie for state law errors)
- Miller‑El v. Cockrell, 537 U.S. 322 (2003) (certificate of appealability standard)
- Slack v. McDaniel, 529 U.S. 473 (2000) (COA: jurists of reason standard)
- Cullen v. Pinholster, 563 U.S. 170 (2011) (AEDPA review limits on new evidence)
- Wiggins v. Smith, 539 U.S. 510 (2003) (counsel’s duty to investigate mitigating evidence)
- McMann v. Richardson, 397 U.S. 759 (1970) (competence of counsel during plea advice)
- Boykin v. Alabama, 395 U.S. 238 (1969) (plea must be voluntary and knowing)
- Parke v. Raley, 506 U.S. 20 (1992) (guilty plea must be a voluntary, intelligent choice)