Donald Medley v. Donnie Ames, Superintendent, Mt. Olive Correctional Complex

Summary

The West Virginia Supreme Court of Appeals affirmed the denial of Donald Medley’s petition for post-conviction habeas corpus relief. The court held that claims concerning the victim’s fingernail scrapings and cellphone had been previously litigated on direct appeal and were barred by the law of the case, collateral estoppel, and res judicata. The court also rejected Medley’s claim that prejudicial trial publicity influenced the jury, finding no showing of juror exposure and concluding that the issue had been waived.

Holdings

1. A petitioner may not raise the same grounds in a direct appeal and a subsequent post-conviction habeas proceeding; Medley's claims concerning the victim's fingernail scrapings and cell phone were previously and finally litigated and were not reviewable again.
2. Medley failed to establish a constitutional due process violation because he did not show that the evidence was favorable, suppressed by the State, or material and prejudicial.
3. A defendant seeking relief based on prejudicial publicity disseminated during trial must show that jurors were exposed to the publicity; when the defendant declines an opportunity to poll the jurors and presents no later evidence of improper influence, the claim is waived.

Questions Presented

1. Whether Medley could relitigate in post-conviction habeas corpus proceedings his claims that the State suppressed or failed to preserve the victim's fingernail scrapings and cell phone after those claims had been decided on direct appeal.
2. Whether Medley established a Brady/Youngblood due process violation concerning the victim's fingernail scrapings or cell phone.
3. Whether alleged prejudicial publicity during trial entitled Medley to habeas relief when he did not poll the jury and presented no evidence that any juror was exposed to or influenced by the publicity.

Disposition

affirmed