Shawn States v. Pelicia Hall, Commissioner
711 F. App'x 198
| 5th Cir. | 2017Background
- Shawn M. States was convicted of two counts of capital murder in Mississippi and sentenced to life; he proceeded pro se on federal habeas under 28 U.S.C. § 2254 after state-court review.
- States challenged denial of habeas relief on several grounds within the granted COA: federal speedy-trial claim; ineffective assistance for failing to raise speedy-trial and to move to suppress an allegedly coerced post-arrest statement; and error in a jury instruction on flight.
- The Mississippi Supreme Court issued a summary ruling denying relief; federal review is therefore governed by AEDPA deference and the Richter standard for unexplained state-court decisions.
- The district court denied § 2254 relief; States appealed. This court reviewed legal issues de novo and factual findings for clear error, applying AEDPA standards.
- Key contested facts: a 36-month delay from arrest (2007) to trial (2010); multiple continuances to which States had agreed; alleged coercive promises relating to States’s girlfriend (Ariana Torrenegra) and his post-arrest statements; and a trial flight instruction that the state court found unwarranted but harmless given the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal speedy-trial violation | Delay (36 months) between arrest and trial violated States’s Sixth Amendment right | Delay was partially the defendant’s fault (multiple continuances); no intentional state delay; defendant did not diligently assert right and failed to show actual prejudice | Denied — Barker factors do not favor States; he abandoned prejudice argument and failed to show constitutional violation |
| Ineffective assistance — failing to raise federal speedy-trial claim | Counsel should have raised a federal speedy-trial claim | Claim was meritless; counsel not ineffective for failing to litigate frivolous issue | Denied — counsel not ineffective for failing to raise meritless federal claim |
| Ineffective assistance — failing to raise state statutory speedy-trial claim | Counsel should have raised Mississippi statutory speedy-trial violation | Mississippi Supreme Court rejected the claim; States fails Strickland prejudice and deficiency prongs | Denied — state-court ruling reasonable; no Strickland relief |
| Ineffective assistance — failing to move to suppress coerced statement | Counsel should have moved to suppress because promises regarding girlfriend coerced confession | Officers had probable cause to implicate/arrest girlfriend; promises were within discretion and did not make confession involuntary | Denied — state-court decision reasonable under AEDPA; statements not shown involuntary |
| Jury instruction on flight violated due process | Flight instruction was improper and deprived due process | Even if instruction was unwarranted, error was harmless given overwhelming evidence | Denied — any error harmless; no federal due process violation |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (four-factor speedy-trial balancing test)
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
- Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference to unexplained state-court rulings)
- Brecht v. Abrahamson, 507 U.S. 619 (1993) (harmless-error standard for habeas relief)
- Rogers v. Richmond, 365 U.S. 534 (1961) (coercion/involuntariness analysis for confessions)
- Allen v. McCotter, 804 F.2d 1362 (5th Cir. 1986) (police warnings about suspects’ associates and voluntariness of confession)
- Yohey v. Collins, 985 F.2d 222 (5th Cir. 1993) (issues not briefed on appeal are abandoned)
- Goodrum v. Quarterman, 547 F.3d 249 (5th Cir. 2008) (delay thresholds and weighing of speedy-trial factors)