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Seghelmeble v. Davis, Director TDCJ-CID
3:14-cv-04377
N.D. Tex.
Apr 19, 2016
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Background

  • Petitioner Juan Seghelmeble stabbed and killed Gladys Reyes; arrested at the scene and later convicted of murder and sentenced to life (conviction affirmed on direct appeal and state habeas denied).
  • Pretrial competency was contested: multiple competency hearings between 2008–2011 with conflicting expert opinions (Dr. Pittman diagnosing paranoid schizophrenia; Dr. Compton finding competency); jury ultimately found him competent after a competency trial.
  • Procedurally, Petitioner filed state habeas relief (denied on trial-court findings) then a federal §2254 petition alleging ineffective assistance of counsel (several variants), incompetency to stand trial, and denial of right to testify.
  • The magistrate judge addressed exhaustion/ procedural-default: some claims were not presented to the Texas Court of Criminal Appeals and thus were procedurally barred absent cause and prejudice or a miscarriage-of-justice showing.
  • On the merits where adjudicated, the court applied AEDPA deference and Strickland standards and concluded counsel was not ineffective (insanity defense investigation was pursued and experts did not support legal insanity; failure-to-inform claim was conclusory), and that petitioner failed to overcome procedural bars for other claims. Recommendation: deny §2254 petition with prejudice.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Ineffective assistance — counsel failed to advise re: case/outcomes Seghelmeble says counsel did not inform him about case consequences or advise him adequately Respondent/record: claim is conclusory; no specifics showing deficient performance or prejudice Denied — conclusory; no showing how lack of information altered outcome
Ineffective assistance — failure to raise insanity defense Counsel failed to pursue/raise insanity at trial Counsel retained expert (Dr. Lisa Clayton) who concluded she could not testify Petitioner was insane; no evidence Petitioner was legally insane Denied — investigation undertaken; no evidence of legal insanity; no Strickland prejudice shown
Competency to stand trial Seghelmeble contends he was incompetent during trial State found claim was barred in state habeas as relitigation; no cause or new reliable evidence of actual innocence Procedurally barred — petitioner failed to overcome default; federal review barred
Denial of right to testify / counsel collusion with court Petitioner claims counsel prevented him testifying and colluded with court Not raised to highest state court; procedurally defaulted Procedurally barred — not exhausted and no excuse shown

Key Cases Cited

  • Coleman v. Thompson, 501 U.S. 722 (1991) (procedural-default doctrine and exhaustion)
  • Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance standard)
  • Williams v. Taylor, 529 U.S. 362 (2000) (AEDPA standards for "contrary to" and "unreasonable application")
  • Schlup v. Delo, 513 U.S. 298 (1995) (actual-innocence gateway to review)
  • Crane v. Johnson, 178 F.3d 309 (5th Cir. 1999) (prejudice standard under Strickland in sentencing context)
  • Lockhart v. Fretwell, 506 U.S. 364 (1993) (prejudice must render proceedings fundamentally unfair or unreliable)
Read the full case

Case Details

Case Name: Seghelmeble v. Davis, Director TDCJ-CID
Court Name: District Court, N.D. Texas
Date Published: Apr 19, 2016
Docket Number: 3:14-cv-04377
Court Abbreviation: N.D. Tex.