United States District Court, D. Delaware
RYANS. SAMANS, Petitioner,
G.R. JOHNSON, Warden, and JOSEPH R. BIDEN, III, Attorney General of the State of Delaware, Respondents.
Ryan S. Samans. Pro se Petitioner.
Maria T. Knoll, Deputy Attorney General, Delaware Department of Justice, Wilmington, Delaware. Attorney for Respondents.
LEONARD P. STARK, District Judge.
Pending before the Court is an Application For A Writ Of Habeas Corpus Pursuant To 28 U.S.C. § 2254 ("Petition") filed by Petitioner Ryan S. Samans ("Petitioner"). (D.I. 2) For the reasons discussed, the Court will dismiss the Petition and deny the relief requested.
In July 2007, witnesses saw Petitioner stab a fourteen-year-old boy and later rob another person while in possession of a shotgun. (D.I. 2, Exh. A: State v. Samans, ID XXXXXXXXXX, Letter Order at 1, Stokes, J. (Del. Super. Ct. April 27, 2009)) As a result, he was arrested and charged with first degree robbery, first degree assault, two counts of possession of a deadly weapon during the commission of a felony, possession of a firearm during the commission of a felony, aggravated menacing, and second degree conspiracy. ( Id. )
On January 9, 2008, Petitioner entered a guilty plea to the charges of first degree robbery, second degree assault, and possession of a firearm during the commission of a felony. The Superior Court sentenced him to a total of fourteen years of incarceration, with credit for time served, suspended after ten years for a period of probation. See Samans v. State, 979 A.2d 1111 (Table), 2009 WL 2634120 (Del. Aug. 27, 2009). Petitioner did not appeal his convictions or sentences.
In February, 2009, Petitioner filed in the Superior Court a motion for post-conviction relief pursuant to Delaware Superior Court Criminal Rule 61 ("Rule 61 motion"). The Superior Court denied the Rule 61 motion, and the Delaware Supreme Court affirmed that decision. See Samans, 2009 WL 2634120. Petitioner filed a second Rule 61 motion, which the Superior Court denied. The Delaware Supreme Court affirmed that decision. See Samans v. State, 45 A.3d 149 (Table), 2012 WL 1970109 (Del. June 1, 2012).
A. The Antiterrorism and Effective Death Penalty Act of 1996
Congress enacted the Antiterrorism and Effective Death Penalty Act of 1996 ("AEDPA") "to reduce delays in the execution of state and federal criminal sentences... and to further the principles of comity, finality, and federalism." Woodford v. Garceau, 538 U.S. 202, 206 (2003) (internal citations and quotation marks omitted). Pursuant to AEDPA, a federal court may consider a habeas petition filed by a state prisoner only "on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States." 28 U.S.C. § 2254(a). AEDPA imposes procedural requirements and standards for analyzing the merits of a habeas petition in order to "prevent federal habeas retrials' and to ensure that state-court convictions are given effect to the extent possible under law." Bell v. Cone, 535 U.S. 685, 693 (2002); see also Woodford, 538 U.S. at 206.
B. Standard of Review
When a state's highest court has adjudicated a federal habeas claim on the merits, a federal court must review a habeas claim under the deferential standard contained in 28 U.S.C. § 2254(d). A claim has been "adjudicated on the merits" for the purposes of 28 U.S.C. § 2254(d) if the state court decision finally resolves the claim on the basis of its substance, rather than on a procedural or some other ground. See Thomas v. Horn, 570 F.3d 105, 115 (3d Cir. 2009).
Pursuant to 28 U.S.C. § 2254(d), federal habeas relief may only be granted if the state court's decision was "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States, " or the state court's decision was an unreasonable determination of the facts based on the evidence adduced in the trial. 28 U.S.C. § 2254(d)(1) & (2); see also Williams v. Taylor, 529 U.S. 362, 412 (2000); Appel v. Horn, 250 F.3d 203, 210 (3d Cir. 2001). This deferential standard of § 2254(d) applies even "when a state court's order is unaccompanied by an opinion explaining the reasons relief has been denied;" as recently explained by the Supreme Court, "it may be presumed that the state ...