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Louis v. Erfe

United States District Court, D. Connecticut

April 14, 2016

CHADWICK J. ST. LOUIS, Petitioner,
v.
MR. ERFE, ET. AL., Respondents.

RULING ON PETITION FOR WRIT OF HABEAS CORPUS

DOMINIC J. SQUATRITO UNITED STATES DISTRICT JUDGE

The petitioner, Chadwick J. St. Louis, an inmate currently confined at MacDougall-Walker Correctional Institution in Suffield, Connecticut, brings this action pro se for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. He challenges his 2009 Connecticut conviction for murder. For the reasons that follow, the petition is denied.

I. Standard of Review

The federal court will entertain a petition for a writ of habeas corpus challenging a state court conviction only if the petitioner claims that his custody violates the Constitution or federal laws. 28 U.S.C. § 2254(a). A claim that a state conviction was obtained in violation of state law is not cognizable in the federal court. See Estelle v. McGuire, 502 U.S. 62, 68 (1991).

Section 2254(d) “imposes a highly deferential standard for evaluating state-court rulings and demands that state-court decisions be given the benefit of the doubt.” Renico v. Lett, 559 U.S. 766, 773 (2010) (citations and internal quotation marks omitted). A federal court cannot grant a petition for a writ of habeas corpus filed by a person in state custody with regard to any claim that was rejected on the merits in state court unless the adjudication of the claim in state court either:

(1) 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; or
(2) 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.

28 U.S.C. § 2254(d). That standard is “difficult to meet.” Metrish v. Lancaster, ____U.S. ____, 133 S.Ct. 1781, 1786 (2013)(internal quotation marks omitted).

Clearly established federal law is found in holdings, not dicta, of the Supreme Court at the time of the state court decision. See Howes v. Fields, ____U.S. ____, 132 S.Ct. 1181, 1187 (2012); Carey v. Musladin, 549 U.S. 70, 74 (2006). Thus, “[c]ircuit precedent does not constitute ‘clearly established Federal law, as determined by the Supreme Court.’” Parker v. Matthews, ____U.S. ____, 132 S.Ct. 2148, 2155 (2012) (quoting 28 U.S.C. § 2254(d)(1)). The clearly established federal law may be a generalized standard or a bright-line rule intended to apply in a particular context. See Kennaugh v. Miller, 289 F.3d 36, 42 (2d Cir. 2002).

A decision is “contrary to” clearly established federal law where the state court applies a rule different from that set forth by the Supreme Court or if it decides a case differently than the Supreme Court on essentially the same facts. Bell v. Cone, 535 U.S. 685, 694 (2002). A state court unreasonably applies Supreme Court law when the court has correctly identified the governing law, but unreasonably applies that law to the facts of the case, or refuses to extend a legal principle clearly established by the Supreme Court to circumstances intended to be governed by the principle. See Davis v. Grant, 532 F.3d 132, 140 (2d Cir. 2008). It is not enough that the state court decision is incorrect or erroneous. Rather, the state court application of clearly established law must be objectively unreasonable, which is a substantially higher standard. See Schriro v. Landrigan, 550 U.S. 465, 473 (2007). Thus, a state prisoner must show that the challenged court ruling “was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility of fairminded disagreement.” Harrington v. Richter, 562 U.S. 86, 103 (2011).

When reviewing a habeas petition, the federal court presumes that the factual determinations of the state court are correct. The petitioner has the burden of rebutting that presumption by clear and convincing evidence. See 28 U.S.C. § 2254(e)(1); Cullen v. Pinholster, 563 U.S. 170, 181 (2011) (standard for evaluating state-court rulings where constitutional claims have been considered on the merits is highly deferential and difficult for petitioner to meet). In addition, the federal court’s review under section 2254(d)(1) is limited to the record that was before the state court that adjudicated the claim on the merits. See Id.

II. Procedural History

In August 2007, police officers arrested the petitioner in connection with the murder of Christopher Petrozza. See State v. St. Louis, 128 Conn.App. 703, 709 (2011). On August 22, 2007, the State’s Attorney filed an information charging the petitioner with one count of murder in violation of Connecticut General Statutes § 53a-54a. See Resp’ts’ Mem. Opp’n Pet. Writ Habeas Corpus, App. B at 3. On March 2, 2009, the State’s Attorney filed a long form information charging the petitioner with one count of murder in violation of Connecticut General Statutes § 53a-54a and one count of tampering with evidence in violation of Connecticut General Statutes § 53a-155(a)(2). See Id. at 12.

On March 3, 2009, at the plea hearing, a judge canvassed the petitioner on his election to waive his right to a jury trial and instead to be tried by a three-judge panel. See Id. App. G, Plea Hr’g, at 1-29, Mar. 3, 2009. On March 10, 2009, the State’s Attorney filed a new information charging the petitioner with one count of murder in violation of Connecticut General Statutes § 53a-54a. See Id. App. B, at 13. The petitioner pleaded not guilty and elected to be tried by a three-judge panel. See Id. App. G, Pre-trial Hr’g, at 1-8, Mar. 10, 2009.

Presentation of evidence began on March 11, 2009. See Id. App. G, Trial Tr., at 24, Mar. 11, 2009. On March 17, 2009, the three-judge panel found the petitioner guilty of murder. See Id. App. G, Trial Tr., at 46, Mar. 17, 2009. On May 27, 2009, the panel of judges sentenced the petitioner to a total effective sentence of fifty years of imprisonment. See Id. App. G, Sentencing Tr., at 45, May 27, 2009.

The petitioner appealed his conviction on six grounds. He claimed that the three-judge panel erred in denying: (1) his motion for a hearing pursuant to Franks v. Delaware, 438 U.S. 154 (1978)[1]; (2) his motion to dismiss on the grounds that the arrest and search warrants were not supported by probable cause and the police failed to properly execute the search warrant; (3) his motion to suppress statements that he gave to police without having received the warnings required under Miranda v. Arizona, 384 U.S. 436 (1966); (4) his motion to suppress physical evidence that had been seized pursuant to an unlawful search warrant; (5) his motion for acquittal on the ground that the State of Connecticut failed to prove beyond a reasonable doubt the exact time or location of the offense or his intent to commit murder; and (6) his motion for a new trial. See St. Louis, 128 Conn.App. at 705-06. On May 17, 2011, the Connecticut Appellate Court affirmed the judgment of the trial court. See Id. at 730. On October 26, 2011, the Connecticut Supreme Court denied the defendant St. Louis’ petition for certification to appeal the decision of the Appellate Court. See State v. St. Louis, 302 Conn. 945 (2011).

In April 2010, the petitioner filed a petition for a writ of habeas corpus in the Connecticut Superior Court for the Judicial District of Tolland at Rockville challenging his conviction on various grounds. See Pet. Writ Habeas Corpus at 5; St. Louis v. Warden, TSR-CV10-4003535-S (Conn. Super. Ct. Apr. 26, 2010). He filed a second state habeas petition in November 2012. See St. Louis v. Warden, TSR-CV13-4005120-S (Conn. Super. Ct. Nov. 1, 2012).[2] A judge subsequently consolidated the second habeas case with the first habeas case. See St. Louis v. Warden, TSR-CV13-4005120-S, Dkt. Entry 104.00 (Conn. Super. Ct. Jan. 15, 2013). On August 4, 2014, after a hearing, the court denied the amended habeas petition filed in the consolidated actions. See St. Louis v. Warden, No. TSRCV104003535, 2014 Conn. Super. LEXIS 1918, at *14 (Conn. Super. Ct. Aug. 4, 2014).

The petitioner appealed the denial of the habeas petition. See St. Louis v. Comm’r of Correction, 161 Conn.App. 358 (2015). On November 17, 2015, the Connecticut Appellate Court dismissed the appeal. See Id. at 367.

The petitioner filed the present federal petition in March 2012. All claims raised in this petition were previously raised on direct appeal. The respondents have filed a memorandum in opposition to the petition.

III. Factual Background

The Connecticut Appellate Court determined that the following facts and procedural history were relevant to the petitioner’s appeal:

Christopher Petrozza worked for the defendant [3] in his landscaping business. Petrozza and the defendant also socialized together outside of the workplace, and the defendant became financially indebted to Petrozza.
On September 14, 2006, Petrozza purchased a 1998 Audi for $5789 in cash. After purchasing the vehicle, Petrozza was short on funds and on September 29, 2006, Petrozza’s mother, with whom he resided, advised him to collect the money that was owed to him by the defendant. On this date, Petrozza went to the defendant’s home in Manchester. While Petrozza was at the defendant’s home, the defendant intentionally caused Petrozza’s death by striking him with a skid-steer loader, commonly known as a “Bobcat.” After killing Petrozza, the defendant took Petrozza’s driver’s license and buried Petrozza’s body in the rear yard of his residence, covering the grave with large ornamental rocks.
After killing Petrozza, the defendant broke into a vehicle parked at his daughter’s day care center and took a purse that contained a checkbook. The defendant went to a credit union and attempted to use Petrozza’s license to cash a check from the stolen checkbook that he had forged and made payable to Petrozza.
On February 19, 2007, the Manchester police arrested the defendant on charges unrelated to the disappearance of Petrozza. The defendant indicated during the booking process that he had information relevant to the individual who was responsible for recent car breakins. Several days later, the defendant told the police that Petrozza was responsible ...

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