Melbrough Williams v. Marcus Pollard, 20-55542

Melbrough Williams was convicted of multiple sexual offenses, robbery, and kidnapping; he received sentencing in July 2014.
Williams filed a federal habeas petition under 28 U.S.C. § 2254 challenging: a ten-year charging delay, prosecutor-elicited racially prejudicial testimony, ineffective assistance of trial and appellate counsel, and cumulative error.
The California Court of Appeal denied Williams’s state habeas petition as untimely under state timeliness rules (In re Reno); Williams did not file state habeas until September 2017.
The district court denied Williams’s § 2254 petition on the merits; the Ninth Circuit reviews de novo but finds the claims procedurally barred unless excused by Martinez v. Ryan.
The Ninth Circuit concluded Williams failed to show the requisite “cause” because his underlying claims lack merit (not “substantial”): no clearly established law or actual prejudice from delay; racially charged testimony was brief, relevant to consent, and not emphasized by the prosecutor.
Because the underlying claims fail on the merits, Williams’s ineffective-assistance and cumulative-error contentions also fail; the Ninth Circuit affirmed.

Issue	Williams' Argument	State's Argument	Held
Charging delay (due process)	Ten-year delay violated due process	Claims untimely; no clearly established federal right; no actual, non-speculative prejudice	Procedurally barred; merits fail — no clearly established law or proven prejudice
Prosecutorial misconduct (racial testimony)	Prosecutor elicited racially prejudicial testimony that infected trial	Testimony was brief, relevant to consent; prosecutor did not emphasize racial predisposition	Not a due process violation; remarks did not render trial unfair
Ineffective assistance of counsel (trial/appellate)	Counsel’s failures caused procedural default and prejudiced Williams	Under Martinez, underlying IAC claims are not substantial; thus no cause to excuse default	IAC claims lack merit; do not excuse procedural default
Cumulative error (due process)	Combined errors denied a fair trial	Underlying errors are not meritorious, so no cumulative prejudice	No cumulative prejudice; claim fails

Jaramillo v. Stewart, 340 F.3d 877 (9th Cir. 2003) (de novo review of habeas denial)
Lambert v. Blodgett, 393 F.3d 943 (9th Cir. 2004) (federal court may affirm on any record-supported ground)
Ayala v. Chappell, 829 F.3d 1081 (9th Cir. 2016) (procedural bar doctrine explained)
Martinez v. Ryan, 566 U.S. 1 (2012) (cause-and-prejudice excuse for procedural default when IAC in initial-review collateral proceedings is substantial)
Wright v. Van Patten, 552 U.S. 120 (2008) (habeas petitioner must point to clearly established federal law)
Darden v. Wainwright, 477 U.S. 168 (1986) (prosecutorial misconduct requires showing remarks rendered trial fundamentally unfair)
In re Reno, 55 Cal.4th 428 (Cal. 2012) (California timeliness rule for habeas petitions)
Bains v. Cambra, 204 F.3d 964 (9th Cir. 2000) (racially prejudicial evidence can violate due process in some contexts)
United States v. Huntley, 976 F.2d 1287 (9th Cir. 1992) (charging delay requires actual, non-speculative prejudice)