Ronald Alan Hummel v. Warden Demetric Godfrey, Attorney General of the State of Montana

Summary

The United States District Court for the District of Montana denied Ronald Alan Hummel’s amended 28 U.S.C. § 2254 habeas petition arising from his Montana felony DUI conviction. The court rejected Hummel’s claims that the prosecution violated Brady v. Maryland and that the state trial court improperly restricted his ability to present a defense by preventing him from calling the prosecutor to impeach a witness. The court granted a certificate of appealability.

Holdings

1. No Brady violation occurred because the allegedly corrected account was disclosed to the defense before trial and therefore was not suppressed by the State.
2. The state court's refusal to allow Hummel to call the prosecutor as an impeachment witness did not violate clearly established federal law and was not objectively unreasonable under § 2254(d).
3. Federal habeas relief was unavailable because the Montana Supreme Court's rejection of Hummel's claims was not contrary to, or an unreasonable application of, clearly established Supreme Court law and was not based on an unreasonable factual determination.

Questions Presented

1. Whether the State violated Brady v. Maryland by suppressing favorable impeachment or exculpatory evidence concerning Smith's alleged prior statement that he had consumed alcohol.
2. Whether the state trial court's refusal to allow Hummel to call the prosecutor as an impeachment witness violated his federal right to present a complete defense.
3. Whether the Montana Supreme Court's rejection of these claims was contrary to, or an unreasonable application of, clearly established federal law under 28 U.S.C. § 2254(d).

Disposition

writ_denied