Goodwin v. Superintendent, Five Points Correctional Facility

Background

Ken Goodwin sought federal review of his New York state conviction under 28 U.S.C. § 2254, the federal statute governing challenges by state prisoners to unconstitutional custody. In 2017, Goodwin pleaded guilty to second-degree manslaughter under an agreement involving a recommended three-to-nine-year sentence concurrent with a sentence he was already serving. The sentencing judge was unwilling to impose the agreed concurrent sentence and gave Goodwin an opportunity to withdraw his plea.

At a later court appearance, Goodwin was present with experienced defense counsel. After an extended exchange, counsel stated that the plea would be withdrawn and confirmed that he was moving to withdraw it. The trial court then ordered the guilty plea withdrawn. Goodwin proceeded to trial and was convicted of second-degree manslaughter and second-degree assault. The trial court imposed a three-to-nine-year sentence on the manslaughter count, a concurrent two-year sentence on the assault count, and two years of post-release supervision.

Goodwin raised both issues on direct appeal in New York state court. The Appellate Division rejected his arguments, and the New York Court of Appeals denied leave to appeal. The federal court concluded that the claims had therefore been adequately presented to the state courts for federal review.

Legal Standard

Under the Antiterrorism and Effective Death Penalty Act, or AEDPA, a federal court generally may not grant habeas relief on a claim decided on the merits by a state court unless the state decision was contrary to clearly established United States Supreme Court law or unreasonably applied that law. State-court factual findings are presumed correct unless rebutted by clear and convincing evidence.

Withdrawal of the Guilty Plea

Goodwin argued that the state trial court violated his federal constitutional rights by failing to obtain his personal assent on the record before withdrawing his guilty plea. The Appellate Division had found that the record did not show that Goodwin lacked consent or had not authorized his lawyer to withdraw the plea.

The district court held that no Supreme Court precedent required a defendant to personally confirm on the record the withdrawal of a guilty plea. It reasoned that Goodwin’s counsel withdrew the plea on the record while Goodwin was present, and that the withdrawal was done in Goodwin’s favor without his objection. The court therefore held that the Appellate Division’s decision was not contrary to, or an unreasonable application of, clearly established federal law.

Self-Defense Jury Instruction

Goodwin also argued that the state trial court violated his constitutional rights by refusing to instruct the jury on self-defense. Federal habeas relief based on a jury-instruction error requires more than showing that an instruction was incorrect or undesirable; the error must have made the trial fundamentally unfair in violation of due process.

The district court applied New York law, under which a person may use deadly force only when reasonably believing that another person is using or is about to use deadly physical force. The court deferred to the state trial court’s factual finding that there was no evidence Goodwin reasonably believed deadly force was necessary. The state court had relied on evidence that the victims were unarmed, including evidence that one victim was trying to flee, and that Goodwin was the first and only person to use a deadly weapon.

The district court agreed that a self-defense instruction was not required under New York law and that the refusal to give one did not violate Goodwin’s federal constitutional rights.

Disposition

The court denied Goodwin’s petition for a writ of habeas corpus. It declined to issue a certificate of appealability because Goodwin had not made a substantial showing that a constitutional right was denied. The clerk was directed to terminate the motion and enter judgment dismissing the case.