Peters v. Madden

Background

Darren Michael Peters filed a self-represented petition under 28 U.S.C. § 2254 challenging his state conviction. The Napa County District Attorney charged him with twenty counts of making criminal threats and five counts of attempted criminal threats, along with prior-conviction allegations. Under a plea agreement, Peters pleaded no contest to five counts of criminal threats and admitted one prior serious felony and one prior strike conviction in exchange for a stipulated sentence of sixteen years and four months and dismissal of the remaining charges and prior-conviction allegations.

The California Court of Appeal affirmed the conviction. Peters later raised a state habeas claim in each level of the California courts. The California Supreme Court denied his petition because it did not include copies of reasonably available documentary evidence. Peters then filed this federal action.

Claim and procedural issue

Peters presented one claim of ineffective assistance of counsel. He argued that counsel failed to obtain his medical records and investigate a possible mental-health defense before advising him to accept the plea offer.

The respondent argued that the claim might be procedurally defaulted because Peters did not raise it on direct appeal and the California Supreme Court denied it under a state procedural rule. The court explained that it could deny a habeas claim on the merits without first resolving a procedural-default question. It chose that approach here because the claim failed on the merits.

Merits analysis

The court applied the federal standard for ineffective assistance of counsel in connection with a plea. Peters had to show both that counsel’s performance fell below an objective standard of reasonableness and that, without the alleged error, there was a reasonable probability that he would have rejected the plea and insisted on a trial.

The court reviewed the California Court of Appeal’s decision under the deferential federal habeas standard. That standard permits relief only when the state court’s decision was contrary to, or an unreasonable application of, clearly established United States Supreme Court law, or was based on an unreasonable determination of the facts.

The court held that the state appellate court reasonably rejected Peters’s claim. Peters’s own declaration stated that he had explained his mental illness in detail to trial counsel, so counsel already knew about his mental-health history. The record also showed that, when investigators questioned him about the threatening letters, Peters said he meant the threats, was willing and able to carry them out, felt completely in control when he wrote them, and understood what he had done. Based on those facts, the court found little chance that a mental-health defense would have succeeded at trial.

The court therefore concluded that Peters had not shown a reasonable probability that obtaining the medical records would have caused counsel to recommend rejecting the plea, or that Peters would then have insisted on going to trial. The state appellate court’s decision was not contrary to, or an unreasonable application of, Supreme Court precedent.

Disposition

The court DENIED the petition for a writ of habeas corpus. It also DENIED a certificate of appealability because Peters had not made the required substantial showing that a constitutional right was denied or shown that reasonable judges would find the court’s constitutional assessment debatable or wrong. The opinion states that Peters may seek a certificate from the Court of Appeals. The clerk was directed to terminate pending motions, enter judgment in favor of the respondent, and close the file.