Jerome Pringle v. Charles Ryan
699 F. App'x 643
9th Cir.2017Background
- Petitioner Jerome Lee Pringle was indicted for first-degree murder and theft of means of transportation; the State sought the death penalty based on aggravating circumstances.
- Petitioner accepted a guilty plea to both counts in exchange for the State to drop the death-penalty request and for the trial court to impose either natural-life or life with parole options.
- The state court accepted the plea and conducted a three-day sentencing hearing, ultimately imposing natural-life imprisonment.
- Petitioner filed pro se post-conviction relief, which the Arizona courts denied, and the Arizona Supreme Court denied review.
- Petitioner then filed a pro se habeas petition under 28 U.S.C. § 2254, raising three grounds, with only the first certified for appeal: ineffective assistance of counsel (IAC).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Petitioner’s IAC claims were properly reviewed under Strickland and AEDPA. | Pringle argues counsel’s performance was deficient and prejudicial. | Respondents argue the Strickland standard, with AEDPA deference, applies and that decisions were reasonable. | IAC claims denied under Strickland and AEDPA standards. |
| Whether discussions about race at plea negotiations rendered counsel deficient. | Pringle contends race-based discussions show deficient performance and coercion. | State asserts race-based discussions were trial strategy, not deficiency. | No deficiency; discussions treated as strategic, not impairing performance. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (sets the IAC standard with substantial deference under AEDPA)
- Premo v. Moore, 562 U.S. 115 (U.S. 2011) (emphasizes Strickland's plea-bargain considerations require deference)
- Hurles v. Ryan, 752 F.3d 768 (9th Cir. 2014) (highly deferential review under AEDPA with Strickland)
- Tollett v. Henderson, 411 U.S. 258 (U.S. 1973) (guilty plea waives claims arising from earlier statements)
- Harrington v. Richter, 562 U.S. 86 (U.S. 2011) (reaffirmed deferential Strickland review under AEDPA)