(HC) Fields v. Cate, 2:11-cv-02205

Fields, a state prisoner, filed a pro se 28 U.S.C. §2254 petition challenging his California murder and assault convictions and life-to-determinable sentence.
State courts denied relief on multiple habeas petitions prior to the federal petition filed August 15, 2011.
Petitioner raised six grounds: (1) eleven-day interruption in jury deliberations; (2) evidentiary rulings; (3) failure to instruct on involuntary manslaughter; (4) ineffective assistance of trial counsel (testing the prosecution’s case); (5) ineffective assistance (other defense failures); (6) prosecutorial misconduct (withholding exculpatory evidence).
The district court denied relief and declined a certificate of appealability; Fields also sought an evidentiary hearing, which was denied under AEDPA §2254(e)(2).
The court conducted an independent, deferential review under AEDPA and found no reasonable application of clearly established federal law in the state courts’ rulings.
The petition was denied on all grounds and judgment was entered against Fields.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eleven-day jury-deliberation interruption	Fields contends the break was improper and prejudicial.	Appellate courts deemed the break discretionary and forfeited; no prejudice shown.	No federal due process violation; no prejudice shown.
Evidentiary rulings and impeachment evidence	Admission of some domestic-violence and impeachment evidence violated due process.	State court applied ordinary evidentiary rules; no fundamental unfairness.	No due process violation; evidence admitted did not render trial fundamentally unfair.
Failure to instruct on lesser-included offense	Due process requires instruction on all necessarily included offenses.	No constitutional mandate to give involuntary-manslaughter instruction in non-capital case.	No relief; not cognizable under federal habeas on this ground.
Ineffective assistance of counsel (trial strategy and prejudice)	Counsel’s omissions denied effective assistance under Strickland.	Court deferentially reviewed; no deficient performance or prejudice shown.	No ineffective-assistance relief; Strickland standard not met.
Prosecutorial misconduct/ Brady-type withholding	Prosecutor knowingly withheld exculpatory materials.	Many materials either nonexistent or not shown to be suppressed; no prejudice established.	No relief; petition denied on Brady-related grounds.

Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (clearly established federal law; AEDPA deference concepts)
Harrington v. Richter, 131 S. Ct. 770 (U.S. 2011) (AEDPA deference; last reasoned decision and independent review)
Cullen v. Pinholster, 131 S. Ct. 1388 (U.S. 2011) (limitations on new evidence in habeas review; record-before-state-court rule)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (defining standard for ineffective assistance of counsel)
Estelle v. McGuire, 502 U.S. 62 (U.S. 1991) (due process limits on evidentiary rules; broad federal review)
United States v. Gaudin, 515 U.S. 506 (U.S. 1995) (jury instructions and element determination principles)