Woods, Rodney Lewis
WR-81,783-02
| Tex. App. | Mar 3, 2015Background
- Petitioner Rodney L. Woods filed a pro se reply to the State’s response to his state habeas application seeking vacatur of convictions/sentences under the Texas post-conviction rules, alleging violations of the Fifth, Sixth, and Fourteenth Amendments.
- Two relevant indictments: (1) Cause No. F-89A4738-QP — originally charged with unlawful delivery of a simulated controlled substance; Woods pled guilty to possession of a simulated substance and waived jury. (2) Cause No. F-90-29380-UP — charged with possession with intent to deliver cocaine; Woods was tried and convicted by a jury in April 1990.
- Woods alleges defense counsel Kenneth Weatherspoon provided ineffective assistance: failed to investigate (no expert fingerprint/DNA/drug analysis), failed to call witnesses, gave erroneous advice about pleas, and failed to pursue a direct appeal.
- The State argued Woods cannot pursue relief in state court because he is apparently in federal custody and raised laches/exhaustion defenses.
- Woods requests the state court to (a) consider constitutional errors as fundamental miscarriage of justice, (b) reject procedural bars where actual innocence or significant constitutional violation exists, and (c) hold an evidentiary hearing and appoint counsel.
Issues
| Issue | Plaintiff's Argument (Woods) | Defendant's Argument (State) | Held |
|---|---|---|---|
| 1. Ineffective assistance during plea/plea advice | Counsel gave constitutionally deficient advice during plea negotiations and failed to investigate plea consequences; Woods would have accepted a different course if properly advised | State disputes merits; points to procedural barriers and custody issues | Court has not issued a ruling in this filing; Woods requests vacatur or evidentiary hearing |
| 2. Failure to investigate and present expert evidence at trial | Counsel did not obtain fingerprint/DNA/drug analyses or call witnesses, depriving adversarial testing under the Sixth Amendment | State urges procedural defenses and seeks affidavit from counsel instead of full relief | No decision in this reply; Woods requests hearing to develop facts |
| 3. Jurisdiction / custody (state vs. federal) | Woods asks state court to consider substance over form and review constitutional defects despite custody status | State contends only federal courts can issue habeas while petitioner is in federal custody and raises exhaustion/laches | No ruling here; petitioner urges state court to proceed or hold hearing |
| 4. Procedural bars (exhaustion, laches, statute of limitations) | Woods urges actual-innocence gateway and cites precedent to overcome procedural bars; asks court to consider fairness over finality | State argues exhaustion and laches should bar merits review | No final disposition in this document; petitioner requests court to apply equitable doctrines to reach merits |
Key Cases Cited
- Haines v. Kerner, 404 U.S. 519 (1972) (liberal construction of pro se pleadings)
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑part ineffective-assistance standard)
- Lafler v. Cooper, 566 U.S. 156 (2012) (ineffective assistance in plea bargaining can prejudice defendant)
- Missouri v. Frye, 566 U.S. 134 (2012) (duty to communicate plea offers; counsel duties in plea process)
- Gideon v. Wainwright, 372 U.S. 335 (1963) (right to counsel fundamental to adversarial testing)
- United States v. Cronic, 466 U.S. 648 (1984) (circumstances where counsel’s failure amounts to structural error)
- Hill v. Lockhart, 474 U.S. 52 (1985) (ineffective-assistance framework for pleas)
- McQuiggin v. Perkins, 569 U.S. 383 (2013) (actual innocence may overcome procedural bar or statute of limitations)
- Gall v. United States, 552 U.S. 38 (2007) (sentencing court must avoid procedural error and reliance on clearly erroneous facts)
- United States v. Tucker, 404 U.S. 443 (1972) (review of sentences allegedly based on inaccurate information)
- Cotton v. United States, 535 U.S. 625 (2002) (plain-error standard for forfeited legal errors)