Ivy v. Bolin

Background

A Ramsey County, Minnesota, jury convicted Rashad R. Ivy in 2016 of second-degree sex trafficking, conspiracy to engage in second-degree sex trafficking, third-degree criminal sexual conduct, domestic assault by strangulation, and second-degree solicitation to practice prostitution. Ivy was initially sentenced to 700 months in prison and, after resentencing, received a final sentence of 433 months.

Ivy filed a petition under 28 U.S.C. § 2254, a federal challenge to a state-court conviction. He raised four grounds: ineffective assistance by trial and appellate counsel, and constitutional challenges to Minnesota Statute § 609.322, subdivision 1a. Magistrate Judge John F. Docherty recommended denying the petition. Ivy filed objections.

Court’s Analysis

The district court reviewed the portions of the recommendation to which Ivy specifically objected. It adopted the recommendation.

For the ineffective-assistance claims, the court held that Ivy had not shown either required part of the test established in Strickland v. Washington: that counsel’s performance fell below an objective standard of reasonableness and that the alleged errors affected the outcome. The court also agreed that Ivy had not shown that the state courts unreasonably applied clearly established federal law. Regarding an alleged conflict, the court noted that the state court found only differences in litigation strategy, not an actual conflict.

For the constitutional challenge in ground three, the court held that Ivy had not raised the challenge in his direct state-court appeal. The court therefore treated the claim as procedurally defaulted, meaning that a state-court procedural failure barred federal review. Although ineffective assistance can sometimes excuse such a default, the court held that Ivy had not shown ineffective assistance sufficient to do so.

For ground four, Ivy argued that the statute violated the Fourteenth Amendment’s Equal Protection Clause because, according to him, 85 percent of defendants sentenced under it were minorities. The court held that the statute did not classify people by race, that Ivy offered no evidence that it disproportionately affected minorities, and that he offered no evidence of discriminatory intent or purpose. The court further held that he had not shown that the state court’s conclusion violated clearly established federal law.

Disposition

Judge Paul A. Magnuson adopted the recommendation, denied Ivy’s petition for a writ of habeas corpus, and dismissed the matter. The court also ruled that a Certificate of Appealability would not issue because Ivy had not made the required substantial showing that a constitutional right had been denied.

The supplied metadata lists the filing date as May 6, 2026, while the opinion is dated May 5, 2026.