Michael Knaubert v. Goldsmith, Warden, et al.

Summary

The Ninth Circuit affirmed the dismissal of Michael Knaubert’s federal habeas corpus petition and the denial of his motion for appointed counsel. The court held that his search-and-seizure claim was barred under Stone v. Powell, the jury instructions adequately placed the burden of proving sanity on the state, the state court’s implicit factual findings supported admission of his confession, his ineffective-assistance claim was procedurally barred, and appointment of counsel was not constitutionally required absent an evidentiary hearing.

Holdings

1. A state prisoner may not relitigate a Fourth Amendment claim in federal habeas when the state courts provided a full and fair opportunity to litigate the search-and-seizure issue.
2. A jury instruction mentioning a presumption of sanity does not violate due process when, considered as a whole, it clearly places on the State the burden of proving the defendant's sanity beyond a reasonable doubt.
3. A federal habeas court need not conduct an evidentiary hearing when the state court's suppression ruling necessarily embodies an implicit factual finding resolving the disputed issue and none of the mandatory Townsend circumstances is present.
4. A federal habeas petitioner whose ineffective-assistance claim is procedurally defaulted in state court must show cause and actual prejudice before obtaining federal habeas relief; failure to show prejudice is independently sufficient to bar the claim.
5. When a district court properly declines to hold an evidentiary hearing, denial of appointed counsel at government expense for a habeas petitioner does not violate due process.

Questions Presented

1. Whether Stone v. Powell barred federal habeas relitigation of Knaubert's Fourth Amendment search-and-seizure claim after a full and fair state-court hearing.
2. Whether the jury instructions concerning the presumption of sanity unconstitutionally shifted the burden of proving sanity to Knaubert.
3. Whether the district court was required to hold a federal evidentiary hearing concerning the voluntariness of Knaubert's confession.
4. Whether Knaubert's ineffective-assistance claim was barred by procedural default absent a showing of cause and actual prejudice.
5. Whether due process required appointment of counsel for Knaubert in his federal habeas proceeding when no evidentiary hearing was held.

Disposition

affirmed