McNatt v. Gamboa

Background

A California jury convicted Christopher McNatt of second-degree murder and found that he used a deadly weapon. He received a total sentence of 36 years to life. The California Court of Appeal affirmed the conviction and later remanded so the trial court could consider whether to strike a five-year enhancement. The California Supreme Court denied review.

McNatt, representing himself in this federal case, filed a petition asking the court to review his state conviction under a federal law that permits challenges to state custody based on violations of federal constitutional or statutory rights. Martin Gamboa, identified as the current warden, was substituted as the respondent for a previous warden.

Claim One: Late Disclosure of Witness Interview

McNatt argued that the prosecution violated his due-process rights by disclosing during trial a December 30 interview of Ronald Arrasmith. McNatt said the interview contained information that could have supported his theory that Arrasmith, rather than McNatt, killed Ronald Sauvageau, or could have helped show that McNatt was only involved in disposing of the body.

The trial court found that the interview was discoverable and that the prosecution had violated discovery orders, but it denied McNatt’s request to dismiss the case because the interview did not exonerate him. The defense was allowed to play portions of the interview for the jury. The state appellate court later concluded that the late disclosure had not prevented the defense from using the material effectively.

The federal court upheld that conclusion under the demanding standard for federal review of claims already decided by a state court. It reasoned that the defense had already pursued the theory that Arrasmith committed the killing, used the interview to challenge Arrasmith’s credibility, and had time to investigate the newly disclosed information or request more time. The court also ruled that, even if McNatt could establish the required prejudice, the late disclosure was harmless because McNatt’s statements to police and his trial testimony provided substantial evidence supporting the conviction. Relief on claim one was denied.

Claim Two: Lawyer’s Handling of DNA Evidence

McNatt argued that his trial lawyer failed to challenge DNA evidence showing that McNatt was excluded from DNA found on several items, while Arrasmith’s DNA appeared on some of them. Although the claim had not been presented to the state courts, the federal court denied it on the merits rather than deciding whether it had been properly exhausted.

Applying the test for ineffective assistance of counsel—whether the lawyer’s performance was objectively unreasonable and whether the alleged error probably affected the result—the court found that counsel had requested the prosecution’s DNA evidence, sought sanctions and additional time concerning late-tested samples, consulted experts, cross-examined the DNA expert, and argued that the DNA evidence supported McNatt’s innocence. The court concluded that counsel’s performance was not deficient. It also found no reasonable probability that different handling of the DNA evidence would have changed the result, given McNatt’s incriminating statements. Claim two was denied on the merits.

Disposition

The court denied the petition. It also denied a certificate of appealability because McNatt had not made the required substantial showing that a constitutional right was denied and had not shown that reasonable judges could debate the court’s assessment of his claims. The court entered judgment in favor of Martin Gamboa, directed the clerk to close the file, and ordered that Gamboa replace the previous warden as the respondent on the docket.