Summary
The United States District Court for the Eastern District of Washington dismissed Grant Thomas McAdams’s amended petition for a writ of habeas corpus under 28 U.S.C. § 2254 with prejudice. The court held that several claims were procedurally defaulted and that the exhausted claims did not satisfy the deferential federal habeas standard, including claims concerning the appellate record, sufficiency of the evidence, ineffective assistance of counsel, and an uncertified interpreter. The court denied an evidentiary hearing, declined to appoint counsel, and denied a certificate of appealability.
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Questions Presented
- Whether claims raised in untimely or unpresented state personal restraint petitions were procedurally defaulted and barred from federal habeas review.
- Whether denial of requested transcripts and alleged deficiencies in the appellate record violated McAdams's constitutional rights.
- Whether the evidence was constitutionally sufficient to support the first-degree robbery conviction.
- Whether trial counsel was ineffective for failing to present additional evidence concerning distance and timing.
- Whether use of an uncertified interpreter violated clearly established federal law.
- Whether McAdams was entitled to appointment of counsel or an evidentiary hearing in the federal habeas proceeding.
- Whether McAdams was entitled to a certificate of appealability.
Holdings
- Claims that were not fairly presented to the state courts or were raised in personal restraint petitions dismissed as untimely under RCW 10.73.090 were procedurally defaulted and could not be reviewed in federal habeas absent cause and prejudice or a fundamental miscarriage of justice.
- The Constitution requires an indigent defendant to receive a record sufficiently complete to permit adequate appellate review, but does not require a complete verbatim transcript or every requested transcript. McAdams failed to show that the missing opening-statement and voir-dire materials were necessary or affected the adequacy or outcome of his appeal.
- The evidence was constitutionally sufficient to support the robbery conviction because, viewed in the light most favorable to the prosecution, a rational juror could infer that McAdams used force as part of a continuous transaction to obtain the vehicle.
- McAdams failed to establish ineffective assistance based on counsel's failure to present additional distance-and-timing evidence because he did not show deficient performance or a reasonable probability of a different result.
- McAdams was not entitled to habeas relief on his interpreter claim because he identified no clearly established Supreme Court authority holding that use of a non-certified interpreter, without more, violates the Constitution.
- There is no constitutional right to counsel in federal habeas proceedings, and McAdams did not demonstrate exceptional circumstances warranting appointment of counsel.
- A certificate of appealability was denied because McAdams did not make a substantial showing of the denial of a constitutional right and reasonable jurists could not disagree with the resolution of his claims.
Key quotations
“The Constitution requires only a “record of sufficient completeness,” not a complete verbatim transcript.” (Discussion § 3)
“Petitioner’s proposed interpretation does not render the jury’s conclusion irrational.” (Discussion § 4)
Factual background
A Spokane County jury found McAdams guilty of first-degree assault and first-degree robbery after evidence showed that he attacked the victim with a wrench, removed him from a vehicle, and drove away in it. The trial evidence included the victim's identification, corroborating eyewitness testimony, and forensic evidence linking McAdams to the vehicle. McAdams did not testify, and defense counsel pursued an alibi defense based on distance and timing.
Procedural history
A Spokane County Superior Court jury convicted McAdams in 2012 and sentenced him to 219 months. The Washington Court of Appeals affirmed on direct review, and the Washington Supreme Court denied review. McAdams later filed multiple personal restraint petitions, several of which were dismissed as untimely; after state collateral proceedings concluded, the federal court lifted its stay, considered the amended petition, dismissed procedurally defaulted claims, rejected the exhausted claims on the merits, denied an evidentiary hearing and appointment of counsel, and denied a certificate of appealability.