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Robert R. Rubish v. Dan Lungren, Attorney General of the State of California James H. Gomez, Director of the Dcd Robert G. Borg, Warden of Folsom Prison

Citations: 24 F.3d 249; 1994 U.S. App. LEXIS 18846; 1994 WL 143127Docket: 93-15616

Court: Court of Appeals for the Ninth Circuit; April 21, 1994; Federal Appellate Court

Narrative Opinion Summary

The case involves a habeas corpus petition filed under 28 U.S.C. § 2254 by an individual challenging a 1989 state conviction for second-degree murder. The petitioner appealed the district court's dismissal of his petition, focusing on two claims. Firstly, he argued that the trial court erred by not establishing a factual basis for his guilty plea. However, the court held that due process does not require a factual basis absent special circumstances, such as a protestation of innocence, which was not present as the petitioner admitted to brandishing a weapon with intent to threaten. Secondly, the petitioner sought to withdraw his guilty plea at sentencing, alleging ineffective assistance of counsel due to inadequate investigation. The court found no merit in this claim, noting the petitioner failed to demonstrate how additional witness testimonies could have impacted his state of mind. Moreover, the court deemed the attorney's decision not to call certain witnesses as a reasonable strategic choice. The Ninth Circuit affirmed the district court's dismissal, with the case submitted on record and briefs, not intended for publication or citation in future cases.

Legal Issues Addressed

Factual Basis Requirement for Guilty Pleas

Application: The court ruled that the due process clause does not necessitate a factual basis for a guilty plea unless there are special circumstances, such as a specific protestation of innocence.

Reasoning: The court ruled that the due process clause does not require a factual basis unless there are special circumstances, such as a specific protestation of innocence.

Ineffective Assistance of Counsel

Application: Rubish's claim of ineffective assistance of counsel was rejected as he failed to demonstrate how the absence of witness testimonies would have influenced his state of mind regarding the incident.

Reasoning: The court found that Rubish did not show how the witnesses' testimonies would have affected his state of mind regarding the shooting incident.

Strategic Decisions of Counsel

Application: The decision by Rubish's attorney not to call certain bartenders as witnesses was considered a reasonable strategic choice.

Reasoning: Additionally, the court noted that the attorney had interviewed bartenders, and the decision not to call them as witnesses was a strategic choice deemed reasonable.