Eason v. Schnell
U.S. District Court, District of Minnesota
Eason v. Schnell
Trial Court Opinion
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Jamil Joshua Eason, File No. 22-cv-1331 (ECT/DJF)
Petitioner,
v. ORDER ACCEPTING REPORT
AND RECOMMENDATION
Commissioner Paul Schnell,
Respondent.
________________________________________________________________________
Petitioner Jamil Joshua Eason commenced this action by filing a petition for a writ
of habeas corpus. ECF No. 1. The case is before the Court on a Report and
Recommendation [ECF No. 16] issued by Magistrate Judge Dulce J. Foster. Magistrate
Judge Foster recommends denying Eason’s petition. R. & R. at 15. Mr. Eason filed
objections to the Report and Recommendation. ECF No. 17. Because Mr. Eason has
objected the Court is required to review the Report and Recommendation de novo pursuant
to 28 U.S.C. § 636(b)(1) and Local Rule 72.2(b)(3). The Court has undertaken that de novo review and concludes that Magistrate Judge Foster’s analysis and conclusions are correct. Mr. Eason’s objections warrant additional comment in one particular respect. Magistrate Judge Foster concluded that a reasonable interpretation of Missouri v. Frye’s “admonition against allowing an offer to expire ‘without advising the defendant’ is that defense counsel must ‘advise’ the defendant of the existence of the plea offer and its terms—the core question at issue in that case.” R. & R. at 10 (citing Missouri v. Frye,566 U.S. 134
(2012)). In doing so, Magistrate Judge Foster cited one definition of “advise” from the Merriam-Webster Dictionary.Id.
(citing Advise, Merriam-Webster, https://www.merriam-webster.com/dictionary/advise (providing as one definition of “advise”: “to give information or notice to”) (accessed on June 7, 2023)). In his objections, Mr. Eason quotes a different Merriam-Webster definition of “advise”: “to give (someone) a recommendation about what should be done.” ECF No. 17 at 10. He argues that Magistrate Judge Foster ignored this second definition. I understand Magistrate Judge Foster’s citation to the first definition to be illustrative of the Minnesota Supreme Court’s interpretation of Frye. See Eason v. State,950 N.W.2d 258
, 267–71 (Minn.
2020). In other words, that another definition exists does not answer whether the
Minnesota Supreme Court’s decision is contrary to or an unreasonable application of
Strickland or Frye. As the Minnesota Supreme Court explained:
The record here shows that Eason’s counsel thoroughly
discussed the implications and consequences of the original
plea offer with Eason. The final offer for a fixed number of
months under the same terms as the State’s initial offer—made
in Eason’s presence—contained no nuance to further explain.
This offer came after Eason had already rejected a more
favorable plea bargain with that same number as the high
range, and had asked his counsel to negotiate a range with a
lower bottom number. As defense counsel testified at the
postconviction hearing, “You know, he—we rejected the 420
to 480, maybe we thought that he would reject the 480 and
without discussion.”
Under these circumstances, where Eason knew of both plea
offers, was thoroughly counseled about the first offer and
rejected it, and defense counsel continued to zealously
advocate for him to receive that potentially better offer, the
district court correctly concluded that Eason failed to meet his
burden of showing that his attorneys’ conduct fell below an
objective standard of reasonableness.
Id. at 270–71. On different facts, more might be required to meet Strickland and Frye. The
Minnesota Supreme Court’s understanding and application of Strickland and Frye to this
case’s facts was neither contrary to these cases nor unreasonable in some respect.
Therefore, based on all the files, records, and proceedings in the above-captioned
matters, IT IS ORDERED THAT:
1. The Objections to the Report and Recommendation [ECF No. 17] are
OVERRULED;
2. The Report and Recommendation [ECF No. 16] is ACCEPTED in full;
3. Petitioner Jamil Joshua Eason’s Petition for a Writ of Habeas Corpus [ECF
No. 1] is DENIED;
4. This matter is DISMISSED WITH PREJUDICE.
LET JUDGMENT BE ENTERED ACCORDINGLY.
Dated: January 9, 2024 s/ Eric C. Tostrud
Eric C. Tostrud
United States District Court Trial Court Opinion
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Jamil Joshua Eason, File No. 22-cv-1331 (ECT/DJF)
Petitioner,
v. ORDER ACCEPTING REPORT
AND RECOMMENDATION
Commissioner Paul Schnell,
Respondent.
________________________________________________________________________
Petitioner Jamil Joshua Eason commenced this action by filing a petition for a writ
of habeas corpus. ECF No. 1. The case is before the Court on a Report and
Recommendation [ECF No. 16] issued by Magistrate Judge Dulce J. Foster. Magistrate
Judge Foster recommends denying Eason’s petition. R. & R. at 15. Mr. Eason filed
objections to the Report and Recommendation. ECF No. 17. Because Mr. Eason has
objected the Court is required to review the Report and Recommendation de novo pursuant
to 28 U.S.C. § 636(b)(1) and Local Rule 72.2(b)(3). The Court has undertaken that de novo review and concludes that Magistrate Judge Foster’s analysis and conclusions are correct. Mr. Eason’s objections warrant additional comment in one particular respect. Magistrate Judge Foster concluded that a reasonable interpretation of Missouri v. Frye’s “admonition against allowing an offer to expire ‘without advising the defendant’ is that defense counsel must ‘advise’ the defendant of the existence of the plea offer and its terms—the core question at issue in that case.” R. & R. at 10 (citing Missouri v. Frye,566 U.S. 134
(2012)). In doing so, Magistrate Judge Foster cited one definition of “advise” from the Merriam-Webster Dictionary.Id.
(citing Advise, Merriam-Webster, https://www.merriam-webster.com/dictionary/advise (providing as one definition of “advise”: “to give information or notice to”) (accessed on June 7, 2023)). In his objections, Mr. Eason quotes a different Merriam-Webster definition of “advise”: “to give (someone) a recommendation about what should be done.” ECF No. 17 at 10. He argues that Magistrate Judge Foster ignored this second definition. I understand Magistrate Judge Foster’s citation to the first definition to be illustrative of the Minnesota Supreme Court’s interpretation of Frye. See Eason v. State,950 N.W.2d 258
, 267–71 (Minn.
2020). In other words, that another definition exists does not answer whether the
Minnesota Supreme Court’s decision is contrary to or an unreasonable application of
Strickland or Frye. As the Minnesota Supreme Court explained:
The record here shows that Eason’s counsel thoroughly
discussed the implications and consequences of the original
plea offer with Eason. The final offer for a fixed number of
months under the same terms as the State’s initial offer—made
in Eason’s presence—contained no nuance to further explain.
This offer came after Eason had already rejected a more
favorable plea bargain with that same number as the high
range, and had asked his counsel to negotiate a range with a
lower bottom number. As defense counsel testified at the
postconviction hearing, “You know, he—we rejected the 420
to 480, maybe we thought that he would reject the 480 and
without discussion.”
Under these circumstances, where Eason knew of both plea
offers, was thoroughly counseled about the first offer and
rejected it, and defense counsel continued to zealously
advocate for him to receive that potentially better offer, the
district court correctly concluded that Eason failed to meet his
burden of showing that his attorneys’ conduct fell below an
objective standard of reasonableness.
Id. at 270–71. On different facts, more might be required to meet Strickland and Frye. The
Minnesota Supreme Court’s understanding and application of Strickland and Frye to this
case’s facts was neither contrary to these cases nor unreasonable in some respect.
Therefore, based on all the files, records, and proceedings in the above-captioned
matters, IT IS ORDERED THAT:
1. The Objections to the Report and Recommendation [ECF No. 17] are
OVERRULED;
2. The Report and Recommendation [ECF No. 16] is ACCEPTED in full;
3. Petitioner Jamil Joshua Eason’s Petition for a Writ of Habeas Corpus [ECF
No. 1] is DENIED;
4. This matter is DISMISSED WITH PREJUDICE.
LET JUDGMENT BE ENTERED ACCORDINGLY.
Dated: January 9, 2024 s/ Eric C. Tostrud
Eric C. Tostrud
United States District Court Reference
- Status
- Unknown