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Civil Rights
Prisoners' Rights
Writ of Habeas Corpus

Jonathan Jason Aaron v. Joe A. Lizarraga, Warden

Published: Dec. 10, 2016 | Result Date: Oct. 30, 2016 | Filing Date: Jan. 1, 1900 |

Case number: 2:16-cv-01326-AG-PLA Bench Decision –  Dismissal

Court

USDC Central


Attorneys

Petitioner

Robyn Bramson
(Wippert and Bramson)

Scott S. Wippert
(Wippert and Bramson)


Respondent

Jonathan M. Krauss
(Office of the Attorney General)

Kamala D. Harris

Lance E. Winters
(Office of the Attorney General)

Gerald A. Engler
(Office of the Attorney General)

Toni R. Johns Estaville
(Office of the Attorney General)


Facts

Inmate Jonathan Aaron filed a habeas petition against Warden Joe Lizarraga, challenging his conviction for first-degree murder and related crimes.

In 2012, a jury convicted Aaron of first-degree murder, personal use of a knife in the murder, and unlawful sexual intercourse with a minor. He received 26 years to life, plus three years. He appealed his conviction and sentence, asserting ineffective assistance of counsel. His appeal was denied. The California Supreme Court summarily denied review. This federal habeas petition followed.

Contentions

PETITIONER'S CONTENTIONS:
Petitioner alleged that his trial counsel performed deficiently in failing to investigate and put forth a defense of guilty by reason of insanity, violating petitioner's Sixth Amendment right to counsel. Trial counsel also allegedly violated petitioner's right to counsel by failing to investigate and assert a mental defense of lack of premeditation/deliberation. Petitioner also contended that trial counsel's reliance on an untenable theory of provocation/voluntary manslaughter resulted in the denial of petitioner's constitutional right to counsel.

RESPONDENT'S CONTENTIONS:
Respondent contended that the California Court of appeal reasonably rejected petitioner's ineffective assistance of counsel claims.

Result

The magistrate judge found the Court of Appeal's determination reasonable and not contrary to clearly established federal law. The judge then recommended the denial of Aaron's habeas petition and the dismissal of the action. The district court accepted the magistrate judge's report and recommendation and dismissed the action accordingly.


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