Reynaldo Ayala v. Kevin Chappell
2016 U.S. App. LEXIS 13241
| 9th Cir. | 2016Background
- In 1985 three men were execution-style murdered at a San Diego body shop; Reynaldo ("Ayala") was convicted in 1988 largely on the testimony of Pete Castillo and Juan Manuel Meza and sentenced to death.
- Meza pleaded guilty to a drug offense and agreed to testify for the prosecution; defense theory was a robbery by other Mexican men (Pendleton shirt) and attempted to keep evidence of Ayala’s Mexican Mafia (EME) affiliation out of trial.
- Defense pursued a deliberate “no-gang” strategy, avoiding witnesses with known or suspected gang ties for fear cross‑examination would inject EME evidence.
- Key events at trial: Rafa (defense witness) initially exculpated Ayala but recanted on rebuttal implicating Ayala and referencing prison “Southern/Northern” groups; Savocchio (inmate) was subpoenaed but not called after the court indicated his testimony could open EME impeachment.
- Ayala raised numerous claims in state and federal habeas petitions, including ineffective assistance of counsel (IAC) for not calling impeachment witnesses, Brady/Napue claims about Meza/Detective Chacon, witness intimidation, trial-court errors, and actual innocence; the district court held a 20-day federal evidentiary hearing and denied relief; Ninth Circuit affirms under AEDPA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| IAC — failure to call impeachment witnesses (Savocchio, others) | Counsel unreasonably declined to call inmates who would impeach Meza/Castillo, prejudicing outcome | Defense made a researched strategic “no-gang” decision to avoid opening door to EME evidence; calling witnesses risked more harm than benefit | Denied — counsel’s strategy was reasonable; no Strickland/AEDPA relief |
| Brady/Giglio re: Meza’s immunity and informant relationship | Prosecution suppressed material impeachment (undisclosed broad/unwritten immunity and Chacon‑Meza relationship) | Written immunity agreement was disclosed; no evidence of undisclosed broad deal; defense knew Meza sought sentencing benefits | Denied — no Brady suppression or materiality shown; claim 76 unexhausted and meritless |
| Witness intimidation / Napue (Chacon pressured Rafa) | Chacon threatened/coerced Rafa into recanting; state failed to correct false testimony | Rafa repeatedly denied threats at trial and at the evidentiary hearing; Hart’s declaration was unsubstantiated | Denied — Webb/Napue not violated; record does not support intimidation or state‑knowing false testimony |
| Other trial errors (exclusion of hearsay from deceased witness, prosecutor remarks, juror bias, penalty‑phase evidence) | Exclusion of Arthur Castro’s statements, prosecutorial invocation of “association”, juror predisposition to death, and admission of an old uncharged murder prejudiced trial | Excluded hearsay lacked Chambers indicia of reliability; prosecutor’s comments were reasonable inferences; juror was not an automatic death‑voter; delay in Casas prosecution caused no prejudice | Denied — no cumulative or individual violation rendering trial fundamentally unfair |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (Ineffective assistance standard: deficiency and prejudice)
- Brady v. Maryland, 373 U.S. 83 (Prosecution duty to disclose favorable/impeachment evidence)
- Harrington v. Richter, 562 U.S. 86 (AEDPA deference to state-court adjudications)
- Cullen v. Pinholster, 563 U.S. 170 (§2254(d)(1) review limited to record before state court)
- Webb v. Texas, 409 U.S. 95 (per curiam) (Government interference with witness testimony may deny due process)
- Chambers v. Mississippi, 410 U.S. 284 (Due process right to present critical, reliable exculpatory evidence)
- Darden v. Wainwright, 477 U.S. 168 (Prosecutorial misconduct standard: comments must so infect trial with unfairness)
- Morgan v. Illinois, 504 U.S. 719 (Juror bias and death‑penalty commitment rule)
- Wiggins v. Smith, 539 U.S. 510 (Counsel’s duty to investigate and make reasonable strategic choices)