United States District Court, M.D. Florida, Jacksonville Division
JOSEPH L. WILLIAMS, Petitioner,
SECRETARY OF THE FLORIDA DEPARTMENT OF CORRECTIONS, et al., Respondents.
TIMOTHY J. CORRIGAN, UNITED STATES DISTRICT JUDGE.
an inmate of the Florida penal system, initiated this case by
filing a Petition for Writ of Habeas Corpus under 28 U.S.C.
§ 2254 (Doc. 1) (Petition). He challenges a 2013
judgment of conviction (Suwannee County) for robbery while
masked and fleeing a police officer in a high speed pursuit.
He was sentenced to serve a total of 30 years in prison.
Respondents filed an Answer (Doc. 13) (Answer) with exhibits
(Docs. 13-1 through 13-3) (Ex.). Petitioner filed a Reply
(Doc. 20) (Reply) and Supplemental Memoranda (Docs. 21, 23).
This case is ripe for review.
Governing Legal Principles
Standard of Review
Antiterrorism and Effective Death Penalty Act (AEDPA) governs
a state prisoner's federal habeas corpus petition.
See Ledford v. Warden, Ga. Diagnostic &
Classification Prison, 818 F.3d 600, 642 (11th Cir.
2016), cert. denied, 137 S.Ct. 1432 (2017).
“‘The purpose of AEDPA is to ensure that federal
habeas relief functions as a guard against extreme
malfunctions in the state criminal justice systems, and not
as a means of error correction.'” Id.
(quoting Greene v. Fisher, 565 U.S. 34, 38 (2011)).
first task of the federal habeas court is to identify the
last state court decision, if any, that adjudicated the
petitioner's claims on the merits. See Marshall v.
Sec'y, Fla. Dep't of Corr., 828 F.3d
1277, 1285 (11th Cir. 2016). The state court need not issue
an opinion explaining its rationale in order for the state
court's decision to qualify as an adjudication on the
merits. See Harrington v. Richter, 562 U.S. 86, 100
(2011). Where the state court's adjudication on the
merits is unaccompanied by an explanation,
the federal court should “look through” the
unexplained decision to the last related state-court decision
that does provide a relevant rationale. It should then
presume that the unexplained decision adopted the same
reasoning. But the State may rebut the presumption by showing
that the unexplained affirmance relied or most likely did
rely on different grounds than the lower state court's
decision, such as alternative grounds for affirmance that
were briefed or argued to the state supreme court or obvious
in the record it reviewed.
Wilson v. Sellers, 138 S.Ct. 1188, 1192 (2018).
state court has adjudicated a petitioner's claims on the
merits, a federal court cannot grant habeas relief unless the
state court's adjudication of the claim was
“contrary to, or involved an unreasonable application
of, clearly established Federal law, as determined by the
Supreme Court of the United States, ” or “was
based on an unreasonable determination of the facts in light
of the evidence presented in the State court proceeding,
” 28 U.S.C. § 2254(d)(1), (2). A state court's
factual findings are “presumed to be correct”
unless rebutted “by clear and convincing
evidence.” Id. § 2254(e)(1).
AEDPA “imposes a highly deferential standard for
evaluating state court rulings” and “demands that
state-court decisions be given the benefit of the
doubt.” Renico v. Lett, 559 U.S. 766, 773
(2010) (internal quotation marks omitted). “A state
court's determination that a claim lacks merit precludes
federal habeas relief so long as fairminded jurists could
disagree on the correctness of the state court's
decision.” Harrington v. Richter, 562 U.S. 86,
101 (2011) (internal quotation marks omitted). “It
bears repeating that even a strong case for relief does not
mean the state court's contrary conclusion was
unreasonable.” Id. [at 102] (citing
Lockyer v. Andrade, 538 U.S. 63, 75 (2003)). The
Supreme Court has repeatedly instructed lower federal courts
that an unreasonable application of law requires more than
mere error or even clear error. See, e.g.,
Mitchell v. Esparza, 540 U.S. 12');">540 U.S. 12, 18 (2003);
Lockyer, 538 U.S. at 75 (“The gloss of clear
error fails to give proper deference to state courts by
conflating error (even clear error) with
unreasonableness.”); Williams v. Taylor, 529
U.S. 362, 410 (2000) (“[A]n unreasonable application of
federal law is different from an incorrect application of
Bishop v. Warden, GDCP, 726 F.3d 1243, 1253-54 (11th
Cir. 2013) (internal citations modified).
Ineffective Assistance of Counsel
Sixth Amendment guarantees criminal defendants the effective
assistance of counsel. That right is denied when a defense
attorney's performance falls below an objective standard
of reasonableness and thereby prejudices the defense.”
Yarborough v. Gentry, 540 U.S. 1, 5 (2003) (per
curiam) (citing Wiggins ...