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Carpio v. Wall

United States District Court, D. Rhode Island

September 18, 2017

ESTEBAN CARPIO, Petitioner,
v.
ASHBEL T. WALL, Respondent.

          MEMORANDUM AND ORDER

          John J. McConnell, Jr. United States District Judge.

         Esteban Carpio filed this petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. ECF No. 1. Mr. Carpio asserts three grounds for his petition: (1) the state court's jury instructions deprived him of due process; (2) he proved, by a preponderance of the evidence, that he was not responsible for his actions; and (3) he was deprived of his Sixth Amendment right to effective trial counsel. The State of Rhode Island has moved to dismiss the petition (ECF No. 6), and Mr. Carpio has objected (ECF No. 10). For the reasons set forth below, the Court grants the State's motion, and the petition is dismissed.

         Background

         Mr. Carpio is a state court prisoner serving sentences imposed for first-degree murder of a police officer; discharging a firearm while committing a crime of violence; and felony assault with a dangerous weapon. The judgments of conviction were affirmed by the Rhode Island Supreme Court. See State v. Carpio, 43 A.3d 1 (R.I. 2012). Mr. Carpio sought, and was denied, post-conviction relief in state court. See Decision, Carpio v. State, No. PM-2012-3716 (R.I. Super. Ct. Feb. 2, 2016) [hereinafter "Decision"], cert, denied, No. SlM6-0086 (R.I. Mar. 6, 2017).[1]Mr. Carpio filed this petition within the one-year durational limit prescribed by 28 U.S.C. § 2244(d).

         Standard of Review

         This Court is aware of the limited review available to Mr. Carpio. Both United States Supreme Court precedent, see, e.g., Cavazos v. Smith, 565 U.S. 1 (2011), and the congressional mandate contained in the Antiterrorism and Effective Death Penalty Act of 1996 ("AEDPA"), Pub. L. No. 104-132, 110 Stat. 1214, restrict federal court review of state court convictions and sentences. AEDPA, as codified in § 2254(d)'s limited review, "reflects the view that habeas corpus is a 'guard against extreme malfunctions in the state criminal justice systems/ not a substitute for ordinary error correction through appeal." Harrington v. Richter, 562 U.S 86, 102-03 (2011) (quoting Jackson v. Virginia, 443 U.S. 307, 332 n.5 (1979) (Stevens, J, concurring in judgment)).

         Where a state court adjudicates a claim on the merits, a federal court may grant habeas relief only if the state court's "adjudication of the claim" was either "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States" or was "based on an unreasonable determination of the facts in light of the evidence presented." 28 U.S.C. § 2254(d). A state court's factual determinations are presumed to be correct, with the petitioner bearing "the burden of rebutting the presumption of correctness by clear and convincing evidence." 28 U.S.C. § 2254(e)(1).

         Jury Instructions

         Mr. Carpio first argues that the Rhode Island Superior Court denied him due process of law by imposing an additional requirement on the availability of an insanity defense. Specifically, Mr. Carpio claims that the state court erred by instructing the jury "that the result satisfy the community's sense of justice, in the discretion of the jury, on a case-specific basis." ECF No. 1 at 5.

         At the close of evidence in Mr. Carpio's trial, the state court instructed the jury on the Rhode Island insanity defense:

[A] person is not responsible for criminal conduct if at the time of such conduct, as a result of mental disease or defect, his capacity either to appreciate the wrongfulness of his conduct or to conform his conduct to the requirements of the law [was] so substantially impaired that he cannot justly be held responsible.

Carpio, 43 A.3d at 7 (second alteration in original). The trial justice "also impressed upon the jury that the question of whether defendant is criminally responsible is a question for the fact finder-the jury-to determine in light of community standards of blameworthiness." Id. The jury rejected Mr. Carpio's insanity defense.

         On appeal, Mr. Carpio argued that, by asking the jurors to consider the "community's sense of justice, " the trial court had imposed a "second tier" to his burden of proof.[2] Id. at 9-10. The Rhode Island Supreme Court rejected this argument. That court held that, because "the degree of 'substantial' impairment required [for the insanity defense] is essentially a legal rather than a medical question . . . the precise degree demanded is necessarily governed by the community sense of justice as represented by the trier of fact." Id. at 11 (quoting State v. Johnson, 399 A.2d 469, 477 (R.I. 1979)). The Rhode Island Supreme Court concluded:

[T]he trial justice's inclusion of language such as "community sense of justice" and "blameworthiness" in the jury instructions did not graft an additional element onto defendant's burden of proof; the language merely elucidated the role of the jury in passing on the merits of the defense. Simply put, "community standards of blameworthiness" constitute the backdrop against which the defendant's degree of impairment is ...

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