United States District Court, E.D. Missouri, Eastern Division
JAMES R. JABLONSKI, Petitioner,
JAMES HURLEY, Respondent.
MEMORANDUM AND ORDER
RONNIE L. WHITE, District Judge.
This matter is before the Court on the Petition of James R. Jablonski for a Writ of Habeas Corpus pursuant to 28 U.S.C. § 2254. The Petition is fully briefed and ready for disposition. Upon review of the Petition, the response to show cause order, and Petitioner's reply, the Court will dismiss the Petition for habeas relief.
On March 17, 2010, a jury in the Circuit Court of the City of St. Louis found Petitioner, James Jablonski, guilty of two counts of robbery in the first degree. (Legal File, Resp't's Ex. B pp. 41, 43) Thereafter, Petitioner filed a motion for acquittal or in the alternative for a new trial. (Id. at pp. 45-46) On April 23, 2010, the court sentenced Petitioner to 10 years' imprisonment on each count, the sentences to run concurrently. (Id. at pp. 47-50) Petitioner filed Notice of Appeal to the Missouri Court of Appeals for the Eastern District on May 3, 2010. On March 8, 2011, the court of appeals affirmed the trial court's judgment, finding that the state presented sufficient evidence from which a trier of fact could reasonably have found Petitioner guilty. (Order, Resp't's Ex. E) On February 21, 2012, Petitioner filed the present petition for habeas relief in federal court. Petitioner is currently serving out his sentence at the Northeast Correctional Center located in Bowling Green, Missouri.
The Court sets forth the following facts as determined by the Missouri Court of Appeals:
On May 10, 2009, Petitioner drove to the Soulard area of St. Louis with Brian Horn to purchase heroin. The transaction fell through, but Horn told Petitioner that he did not come down for nothing and was going to get something. Petitioner denied having knowledge that Horn planned to rob two victims walking toward their car. The victims testified that Petitioner and Horn approached them together before Horn demanded their purses and displayed what the victims believed to be the barrel of a gun. Petitioner did not speak or display a weapon, and he began to walk away before Horn took the victims' purses. Nevertheless, Petitioner waited down the street for Horn, and the two men fled together on foot. Petitioner drove them away as Horn discarded some of the stolen items out of Petitioner's car window. Later, Petitioner made calls from one of the victims' cell phones and negotiated the sale of an iPod procured during the robbery. The jury found Petitioner guilty of first degree robbery based on an accomplice liability theory. (Resp't's Ex. E pp. 4-5)
In his Petition under 28 U.S.C. § 2254 for a Writ of Habeas Corpus, Petitioner raises one claim for federal habeas relief. He alleges that there was an insufficient evidence to support his first degree robbery convictions under accomplice liability based on the evidence and testimony presented at trial, resulting in a violation of his constitutional right to due process.
Under the Anti-Terrorism and Effective Death Penalty Act (AEDPA), federal courts review state court decisions under a deferential standard. Owens v. Dormire, 198 F.3d 679, 681 (8th Cir. 1999). "[A] district court shall entertain an application for a writ of habeas corpus... only on the ground that [the petitioner] is in custody in violation of the Constitution or laws or treaties of the United States." 28 U.S.C. § 2254(a). A federal court may not grant habeas relief unless the claim adjudicated on the merits in state court "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.'" Owens, 198 F.3d at 681 (quoting 28 U.S.C. § 2254(d)(1)). In addition, 28 U.S.C. § 2254(d)(2) provides that a federal court may not grant the petition unless the adjudication "resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding." "Thus, habeas relief can be available if the conviction at issue is based on findings of fact that could not reasonably be derived from the state court evidentiary record. However, factual findings by the state courts are presumed to be correct." Barnes v. Hammer, 765 F.3d 810, 814 (8th Cir. 2014) (citing 28 U.S.C. §§ 2254(d)(2) and (e)). The petitioner has the "burden of rebutting the presumption of correctness by clear and convincing evidence." 28 U.S.C. § 2254(e)(1); see also Gee v. Groose, 110 F.3d 1346, 1351 (8th Cir. 1997) (state court factual findings presumed to be correct where fairly supported by the record).
The undersigned finds that the decision of the state court was based upon a reasonable determination of the facts in light of the evidence presented at Petitioner's trial. In reviewing a sufficiency of the evidence claim, federal scope of review is extremely limited. Sera v. Norris, 400 F.3d 538, 543 (8th Cir. 2005) (citation omitted). The relevant question is not whether this Court believes the trial evidence established guilt beyond a reasonable doubt but "whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.'" Id. (quoting Jackson v. Virginia, 443 U.S. 307, 319 (1979)); see also Cavazos v. Smith, 132 S.Ct. 2, 3 (2011) ("it is the responsibility of the jury - not the court - to decide what conclusions should be drawn from evidence admitted at trial.").
Here, Petitioner raised his insufficient evidence claim on direct appeal, and after reviewing the record and the parties' briefs, the Missouri Court of Appeals concluded that sufficient evidence existed such that a reasonable juror could have found Petitioner guilty of first degree robbery under an accomplice liability theory. (Resp't's Ex. E pp. 4-5) Specifically, the court found:
When examining the evidence in the light most favorable to the verdict, we find there was ample support in the record to sustain Appellant's convictions under an accomplice liability theory. Appellant testified he and Horn were in Soulard attempting to buy heroin. When the transaction fell through, Horn told Appellant, "I'm not coming down for nothing; I'm going to get something." Horn made this statement after they noticed the victims walking toward their car. Appellant denied having any knowledge Horn intended to commit a robbery at this point. However, "[t]he evidence need not establish a defendant's specific knowledge of ...