Medley v. Baltazar
Civil Action No. 2017-1168
| D.D.C. | Aug 7, 2017Background
- Petitioner Louis M. Medley, III was convicted in D.C. Superior Court of first-degree murder while armed and related offenses and is serving an aggregate 840-month sentence.
- Medley filed a federal habeas petition under 28 U.S.C. § 2254 alleging ineffective assistance of trial counsel for failing to discover and present evidence of his mental health.
- He argued that evidence of mental illness would have shown incompetence to stand trial, temporary insanity at the time of the offenses, innocence, or otherwise negated criminal liability, and sought vacation of the indictment counts and immediate release.
- The court noted that for § 2254 purposes D.C. local courts count as state courts, but D.C. prisoners must first use the local statutory remedy under D.C. Code § 23-110 unless that remedy is inadequate or ineffective.
- The court found that § 23-110 is the standard and adequate remedy for claims of ineffective assistance (including claims implicating actual innocence), and therefore Medley’s federal petition must be dismissed for lack of federal forum availability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Availability of federal habeas under § 2254 for a D.C. prisoner who alleges ineffective assistance of counsel | Medley: federal habeas available because counsel’s failures deprived him of constitutional rights warranting relief | Respondent: D.C. prisoner must use local remedy under D.C. Code § 23-110; federal forum unavailable unless local remedy inadequate | Court: D.C. petitioner must pursue § 23-110 first; federal petition dismissed as local remedy is adequate |
| Adequacy of D.C. Code § 23-110 to raise ineffective-assistance and actual-innocence claims | Medley: counsel’s failure to present mental-health evidence could show incompetence/insanity/innocence, meriting federal relief | Respondent: § 23-110 is the standard, adequate vehicle to test these claims in D.C. courts | Court: § 23-110 is neither inadequate nor ineffective for such claims; federal court will not entertain § 2254 petition |
Key Cases Cited
- Milhouse v. Levi, 548 F.2d 357 (D.C. Cir.) (D.C. local courts treated as "state courts" for § 2254 purposes)
- Garris v. Lindsay, 794 F.2d 722 (D.C. Cir.) (D.C. prisoner lacks federal habeas recourse unless local remedy is inadequate or ineffective)
- Garmon v. United States, 684 A.2d 327 (D.C. 1996) (motion under § 23-110 is the standard means to raise ineffective-assistance-of-counsel claims)