Lyndall Thompson v. Charles Ryan
700 F. App'x 575
| 9th Cir. | 2017Background
- Lyndall Dwaine Thompson, an Arizona inmate convicted of second-degree murder, filed a 28 U.S.C. § 2254 habeas petition challenging his conviction and the PCR court's rulings; the Ninth Circuit affirmed denial of relief.
- Thompson claimed his custodial statements should have been suppressed because he did not validly waive Miranda rights and that counsel was ineffective for not moving to suppress.
- He also alleged the government used a false/altered recording/transcript of his interview to secure conviction, pointing to differences between two transcripts (one prepared by police, one by defense counsel).
- The PCR court found (and the district court relied on) that Thompson voluntarily waived Miranda, that differences between transcripts were formatting not redactions, and that counsel’s investigation and questioning reflected reasonable trial strategy or, alternatively, produced no prejudice.
- Thompson sought an evidentiary hearing; the PCR and district courts denied it, concluding the record resolved disputed issues and no material factual disputes required supplementation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of Miranda waiver | Thompson: did not validly waive right to remain silent; statements should be suppressed | State: waiver was knowing and voluntary; statements admissible | Court: waiver valid; suppression motion not required; counsel not ineffective |
| Ineffective assistance (failure to move to suppress) | Thompson: counsel unreasonably failed to move to suppress custodial statements | State: counsel’s choices were reasonable strategy; no prejudice shown | Court: PCR reasonably applied Strickland; no relief |
| Alleged use of false/altered recording/transcript | Thompson: government used altered/redacted transcript to mislead jury | State: both transcripts contain full interview; differences due to formatting; no alteration shown | Court: PCR reasonably found minimal formatting differences; no false-evidence claim established |
| Request for evidentiary hearing | Thompson: factual disputes (e.g., transcript alterations) required live evidence | State: no material factual disputes; record was sufficient | Court: denial of hearing not unreasonable; district court did not abuse discretion |
Key Cases Cited
- Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference to state-court decisions)
- Woodford v. Visciotti, 537 U.S. 19 (2002) (federal courts give state rulings benefit of the doubt)
- Berghuis v. Thompkins, 560 U.S. 370 (2010) (Miranda rights can be waived knowingly and voluntarily)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance-of-counsel test)
- Hibbler v. Benedetti, 693 F.3d 1140 (9th Cir. 2012) (evidentiary-hearing denial when record suffices)
- Schriro v. Landrigan, 550 U.S. 465 (2007) (district court discretion to deny evidentiary hearing under AEDPA)
- Totten v. Merkle, 137 F.3d 1172 (9th Cir. 1998) (standards for evidentiary hearings in habeas proceedings)