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