Wright v. MaCauley, 2:21-cv-10688

Background

Timothy Wright was convicted in Michigan state court of first-degree premeditated murder, felon in possession of a firearm, and felony-firearm (second offense) after a bench trial related to a shooting inside a gas station.
Video evidence showed Wright chasing and shooting the victim, Deangelo Turner, as Turner fled and then lay on the ground; Wright claimed self-defense, but the court found this unsupported by the evidence.
Michigan appellate courts affirmed the conviction; post-conviction relief motions were denied, including those raising claims based on supposed newly discovered video evidence and alleged ineffective assistance of counsel.
Wright filed a federal habeas petition under 28 U.S.C. § 2254, raising five main grounds including ineffective assistance, trial errors regarding evidence/witnesses, prosecutorial misconduct, and constitutional violations.
The district court reviewed all claims substantively for judicial economy, despite procedural and timeliness arguments from the State, and denied the petition with prejudice.

Issues

Issue	Petitioner’s Argument	Respondent’s Argument	Held
Ineffective Assistance of Counsel (appellate & trial)	Appellate counsel failed to raise trial counsel’s ineffectiveness over witness absence and plea bargaining; trial counsel failed to call exculpatory witness or negotiate plea.	Wright did not provide evidence of what the absent witness would have offered; no indication prosecution interfered; failure to negotiate plea not prejudicial since no evidence Wright would accept plea.	Denied; no showing of deficient performance or prejudice as required under Strickland.
Denial of Evidentiary Hearing on New Evidence	Court erred by not holding hearing on newly discovered video evidence in post-conviction motion.	Claims regarding post-conviction procedures are not cognizable on federal habeas; no constitutional right to such hearings.	Denied; errors in state collateral proceedings not proper subject of federal habeas.
Newly Discovered Evidence/Actual Innocence	New video evidence would show victim had weapon/support self-defense or manslaughter.	Video shows victim fleeing and unarmed at point of shooting; alleged new evidence does not establish innocence or entitlement to relief.	Denied; no constitutional violation or actual innocence shown.
Brady Violation (Suppression of Exculpatory Evidence)	Prosecution withheld/store video showing victim had weapon/another took it, undermining self-defense claims.	No evidence prosecution suppressed exculpatory material; videos do not exculpate Wright.	Denied; no Brady violation; no material suppression.

Key Cases Cited

Williams v. Taylor, 529 U.S. 362 (federal habeas standard: 'contrary to' or 'unreasonable application' of Supreme Court precedent)
Strickland v. Washington, 466 U.S. 668 (ineffective assistance of counsel standard)
Brady v. Maryland, 373 U.S. 83 (suppression of exculpatory evidence by prosecution violates due process)
Cullen v. Pinholster, 563 U.S. 170 (federal habeas review limited to state court record)
Herrera v. Collins, 506 U.S. 390 (actual innocence alone not a ground for federal habeas)

Conclusion: Petition for habeas corpus is denied with prejudice; certificate of appealability and leave to appeal in forma pauperis also denied.