Hollingsworth v. Nines

Summary

The United States District Court for the District of Maryland denies Mark Hollingsworth’s petition for a writ of habeas corpus under 28 U.S.C. § 2254, challenging his Maryland convictions for murder, assault, and related handgun offenses. The court finds the petition timely because an unresolved state sentence-modification motion tolled the AEDPA limitations period, but rejects Hollingsworth’s Brady and ineffective-assistance claims on the merits. The court also declines to issue a certificate of appealability.

Holdings

1. An unresolved, timely Maryland Rule 4-345 sentence-modification motion constituted a collateral proceeding that tolled AEDPA's one-year limitations period, making the federal habeas petition timely.
2. Hollingsworth was not entitled to federal habeas relief on his Brady claim because the state courts reasonably found that defense counsel knew of or had reviewed the detective notes, and the alleged nondisclosure therefore did not establish a Brady violation.
3. The state courts reasonably rejected Hollingsworth's ineffective-assistance claim because counsel's decision not to use the detective notes was a reasonable strategic choice and Hollingsworth failed to show prejudice under the doubly deferential AEDPA and Strickland standards.
4. Hollingsworth was not entitled to habeas relief based on the prosecutor's elicitation of Detective Wiedefeld's testimony because he did not show that the testimony was false, that the prosecutor knew it was false, or that it was material.
5. The prosecutor's closing argument was not an unreasonable application of settled federal law because it was confined to Hollingsworth's recorded statement and the evidence presented to the jury.
6. A certificate of appealability was denied because Hollingsworth did not make a substantial showing of the denial of a constitutional right.

Questions Presented

1. Whether the federal habeas petition was timely under AEDPA because Hollingsworth's unresolved Maryland sentence-modification motion tolled the limitations period.
2. Whether the state courts unreasonably rejected Hollingsworth's Brady claim concerning allegedly undisclosed detective notes.
3. Whether the state courts unreasonably rejected Hollingsworth's ineffective-assistance claim based on counsel's failure to use the detective notes and object to the prosecutor's closing argument.
4. Whether the state courts unreasonably rejected Hollingsworth's prosecutorial-misconduct claims based on alleged use of false testimony and allegedly misleading closing argument.
5. Whether Hollingsworth made the showing required for a certificate of appealability.

Disposition

other