Randal Bernard McCoy v. Warden Joseph H. Headly, et al.

Summary

The United States District Court for the Northern District of Alabama adopted the magistrate judge’s report and recommendation and dismissed with prejudice Randal Bernard McCoy’s 28 U.S.C. § 2254 habeas petition. The court rejected McCoy’s procedural-default, ineffective-assistance, sufficiency-of-the-evidence, evidentiary-hearing, and other objections, including challenges to trial counsel’s stipulation that he had COVID-19. The court also denied a certificate of appealability.

Holdings

1. McCoy's unexhausted claims and claims rejected by the Alabama Court of Criminal Appeals under independent and adequate state procedural grounds were procedurally defaulted and could not support federal habeas relief.
2. McCoy failed to establish actual innocence sufficient to invoke the miscarriage-of-justice exception to procedural default.
3. The Alabama Court of Criminal Appeals' alternative determination that several claims were waived under Rule 28(a)(10) was not manifestly unfair on the facts presented.
4. The state courts reasonably applied Strickland v. Washington and reasonably determined the facts in rejecting McCoy's claim that counsel was ineffective for stipulating that McCoy had COVID-19 and failing to introduce additional medical evidence.
5. McCoy failed to show that counsel's alleged deficiencies in trial preparation or discovery were objectively unreasonable or prejudicial.
6. The Alabama Court of Criminal Appeals reasonably applied the governing constitutional standard in rejecting McCoy's sufficiency-of-the-evidence challenge, and the federal court had to defer to the jury's credibility determinations and weighing of the evidence.
7. McCoy was not entitled to an evidentiary hearing because the facts necessary to resolve his claims were contained in the existing record.
8. McCoy was not entitled to a certificate of appealability because he did not make a substantial showing of the denial of a constitutional right.

Questions Presented

1. Whether claims that were unexhausted or rejected by the Alabama courts on independent and adequate state-law grounds were procedurally defaulted.
2. Whether McCoy established actual innocence sufficient to overcome procedural default.
3. Whether the Alabama Court of Criminal Appeals' application of Alabama Rule of Appellate Procedure 28(a)(10) constituted a basis to excuse procedural default.
4. Whether trial counsel was constitutionally ineffective for stipulating that McCoy had COVID-19, failing to introduce medical evidence, and allegedly failing to prepare adequately for trial and discovery.
5. Whether the evidence was constitutionally sufficient to support McCoy's conviction.
6. Whether McCoy was entitled to an evidentiary hearing or a certificate of appealability.

Disposition

dismissed