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Whitten v. Allen

Citations: 727 F. Supp. 28; 1989 U.S. Dist. LEXIS 15748; 1989 WL 158475Docket: Civ. No. 89-0065-B

Court: District Court, D. Maine; December 14, 1989; Federal District Court

Narrative Opinion Summary

The case involves a petitioner seeking federal habeas corpus relief under 28 U.S.C. 2254 after being convicted of multiple sexual offenses and receiving an 18-year sentence. The primary legal issue is the petitioner's failure to exhaust state remedies, as he did not appeal an adverse post-conviction decision that rejected claims of ineffective counsel, a due process violation, and a denial of a speedy trial. The petitioner asserted ignorance of his right to appeal, arguing procedural default should be excused due to his attorney's failure to inform him of his rights. However, the Court found this did not establish 'cause' for procedural default, noting that ineffective assistance claims must be pursued in state court first. The Court affirmed the magistrate's decision to dismiss the habeas petition without prejudice, emphasizing that federal habeas corpus is an extraordinary remedy, only available after state remedies are exhausted. The petitioner's failure to demonstrate cause and prejudice precluded relief, and his request for the appointment of counsel was also denied. As a result, the petition for a writ of habeas corpus was denied, and the petitioner was barred from federal relief due to procedural default.

Legal Issues Addressed

Cause and Prejudice Standard

Application: Petitioner must demonstrate cause for procedural default and resulting prejudice, which he failed to do, as he did not claim ineffective assistance of counsel.

Reasoning: A federal habeas corpus petitioner who does not exhaust state remedies through procedural default cannot have their constitutional claim reviewed unless they demonstrate cause for the default and resulting prejudice.

Exhaustion of State Remedies under 28 U.S.C. 2254

Application: The petitioner failed to exhaust state remedies by not appealing the adverse post-conviction review judgment, which is a prerequisite for federal habeas corpus relief.

Reasoning: The Honorable Edward H. Keith found that Petitioner did not exhaust his state court remedies by failing to appeal an adverse post-conviction review judgment, mandating that certain claims must be pursued in state court.

Federal Habeas Corpus as an Extraordinary Remedy

Application: Federal habeas corpus is only available after all state remedies are exhausted, underscoring its role as a last resort.

Reasoning: The discussion emphasizes that federal habeas corpus serves as an extraordinary remedy and underscores the importance of exhausting state remedies before seeking federal intervention.

Procedural Default in Habeas Corpus Petitions

Application: The petitioner's procedural default, due to failure to appeal, bars the issuance of a writ of habeas corpus unless cause and prejudice are shown.

Reasoning: The Court agrees with the magistrate's determination that Petitioner’s procedural default bars the issuance of a writ of habeas corpus.

Right to Counsel and Procedural Default

Application: The petitioner claimed his attorney's failure to inform him of his appeal rights constituted 'cause' for procedural default, but without claiming ineffective assistance, this argument fails.

Reasoning: The petitioner’s claim that his attorney's failure to inform him of his rights constitutes 'cause' for the procedural default is not recognized under the exhaustion doctrine.