Timothy Eric Buford v. Raybon Johnson

Summary

The United States District Court for the Central District of California accepted a Report and Recommendation recommending denial of Timothy Eric Buford’s 28 U.S.C. § 2254 habeas petition. The court rejected claims concerning allegedly false firearm evidence, Brady violations, self-representation, ineffective assistance and conflicts of counsel, Batson, evidentiary and instructional rulings, involuntary statements, prosecutorial misconduct, and sufficiency of the evidence. The court also denied related motions and ordered the action dismissed with prejudice.

Holdings

1. Buford was not entitled to habeas relief because he failed to show that the firearm evidence was false or material.
2. Buford failed to establish a Brady violation.
3. The trial court did not violate Buford's right to self-representation by terminating his pro se status and reappointing counsel.
4. Buford failed to establish ineffective assistance of counsel under Strickland.
5. Buford failed to show an actual conflict of interest or an irreconcilable conflict with counsel.
6. Buford failed to establish a prima facie case of purposeful discrimination in the strike of the African American prospective juror.
7. Restriction of evidence concerning the value of the stolen guitar did not establish a Confrontation Clause violation.
8. Buford failed to show that exclusion of the proposed witness testimony violated his right to present a defense.
9. Buford failed to show that his incriminating statements were involuntary.
10. Buford failed to establish instructional error.
11. The evidence was sufficient for a rational jury to find Buford guilty of burglary.
12. Buford's claim that his sentence fell outside the spirit of California's Three Strikes Law was not cognizable in federal habeas proceedings because it presented a state-law issue.
13. Displaying the state seal during closing argument did not establish prosecutorial misconduct warranting habeas relief.
14. The court denied discovery and an evidentiary hearing because Buford did not show colorable entitlement to relief and the existing record was sufficient to resolve the claims.

Questions Presented

1. Whether Buford was entitled to habeas relief based on allegedly false and material firearm evidence and testimony under Napue v. Illinois.
2. Whether the prosecution violated Brady v. Maryland by suppressing alleged false firearm evidence and information about the victim's history as a witness.
3. Whether termination of Buford's self-representation status and reappointment of counsel violated Faretta v. California.
4. Whether trial, preliminary-hearing, and appellate counsel were ineffective under Strickland v. Washington.
5. Whether Buford was denied conflict-free counsel because of an actual conflict or irreconcilable conflict with his attorneys.
6. Whether the prosecutor discriminatorily struck an African American prospective juror in violation of Batson v. Kentucky.
7. Whether restrictions on impeachment evidence concerning the value of the stolen guitar violated the Confrontation Clause.
8. Whether exclusion or restriction of proposed witness testimony violated Buford's right to present a defense.
9. Whether Buford's statements to police were involuntary.
10. Whether the jury instructions were misleading or otherwise constitutionally erroneous.
11. Whether the evidence was sufficient to support Buford's burglary conviction under Jackson v. Virginia.
12. Whether Buford's challenge to California's Three Strikes Law was cognizable in federal habeas proceedings.
13. Whether the prosecutor committed misconduct by displaying the state seal during closing argument.
14. Whether the district court should permit a reply, authorize discovery, or conduct an evidentiary hearing.

Disposition

dismissed