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April 26, 2002


The opinion of the court was delivered by: Ruben Castillo, United States District Judge.



When considering a habeas corpus petition, the Court presumes that the factual determinations of the state court are correct. 28 U.S.C. § 2254(e)(1). Accordingly, we adopt the facts as set forth by the Illinois Appellate Court. People v. Snyder, No. 1-98-4535 (Ill. App. Ct. 2000). Following his trial, Snyder appealed his conviction, and the Office of the Public Defender filed a motion to withdraw as counsel. The Illinois Appellate Court granted counsel's motion to withdraw and affirmed Snyder's convictions and sentences. People v. Snyder, No. 1-97-2297 (Ill. App. Ct. 1998). Snyder did not file a petition for leave to appeal to the Illinois Supreme Court.

On August 28, 1998, Snyder filed a pro se petition for post-conviction relief (R. 11, Answer to Habeas Pet., Ex. B, Post-Conviction Pet.) He alleged that at the time of his trial and his sentencing, he was ingesting three psychotropic medications (Elavil, Sinequan and Prozac). and, thus, he was unfit to stand trial. (Id. at 2.) Additionally, Snyder alleged that, during various meetings with his attorney, he communicated that he was "unable to concentrate on/or recall the events of the alleged crime." (Id. at 3.) On October 23, 1998, the trial court dismissed Snyder's petition as frivolous and patently without merit for lack of supporting documentation.*fn1 (Id., Ex. C, Order Den. Post-Conviction Pet. at 5.)

Snyder appealed the trial court's dismissal of his post-conviction petition. He contended that: (1) he only had to allege, not necessarily prove, that he was ingesting psychotropic medications at the time of trial; and (2) he properly alleged an ineffective assistance of counsel claim. (Id., Ex. D, Pet'r's. Br. on Appeal at 6.) The Illinois Appellate Court affirmed the dismissal of Snyder's post-conviction petition. (Id., Ex. G, Appellate Order Den. Post-Conviction Pet. at 6.) Snyder filed a petition for rehearing, which was subsequently denied. (Id., Ex. I, Order Den. Reh'g.)

On February 16, 2001, Snyder filed a petition for leave to appeal to the Illinois Supreme Court. (Id., Ex. J, Pet. for Leave to Appeal.) Snyder argued that where a petitioner alleges that he notified his attorney of his difficulty concentrating and also alleges the ingestion of three psychotropic medications, he sufficiently shows a constitutional violation. (Id., at 6.) Snyder's petition further contended that the Illinois Supreme Court should clarify its holding in People v. Mitchell, 727 N.E.2d 254, 266-67 (2000) (holding that a defendant's ingestion of psychotropic medication, without more, does not give rise to a bona fide doubt of the defendant's fitness requiring the trial court to order a fitness hearing). Snyder urged the Illinois Supreme Court to hold that although a defendant's ingestion of psychotropic medications does not entitle that defendant to a fitness hearing, it is not irrelevant to the determination of whether that defendant should receive a fitness hearing. (Id. at 3.) On April 4, 2001, the Illinois Supreme Court denied Snyder's petition for leave to appeal. (Id., Ex. K, Order Den. Pet. for Leave to Appeal.)

On September 15, 2001, Snyder filed the instant pro se petition for a writ of habeas corpus. Snyder now claims that: (1) his Sixth Amendment rights were violated when he stood trial while unfit due to his ingestion of psychotropic medications; and (2) he was denied his Sixth Amendment right to effective assistance of counsel where counsel knew that Snyder was medicated, was told by Snyder that he could not understand what was happening in court, and counsel failed to request a fitness hearing or advise the court of his mental status. (R. 1-1, Habeas Pet. at 5.)


Federal courts may grant a writ of habeas corpus when a person is held in custody under a state court judgment in violation of the United States Constitution. 28 U.S.C. § 2254. Before a federal court will consider a petition for a writ of habeas corpus on its merit, however, the petitioner must: (1) exhaust all remedies available in state courts, 28 U.S.C. § 2254(b)(1)(A); and (2) fairly present any federal claims to the state courts first, or risk procedural default, Picard v. Connor, 404 U.S. 270, 275 (1971); Verdin v. O'Leary, 972 F.2d 1467, 1472-73 (7th Cir. 1992). This exhaustion requirement is "grounded in principles of comity; in a federal system, the States should have the first opportunity to address and correct alleged violations of state prisoner's federal rights." Coleman v. Thompson, 501 U.S. 722, 731 (1991). Notwithstanding a procedural default, habeas review may still be available if the petitioner can show cause for the default and actual prejudice, or demonstrate that a failure to consider the claim will result in a fundamental miscarriage of justice. Id. at 750.

The standard of review for claims that survive the exhaustion and procedural default analysis is strict. Under the Antiterrorism and Effective Death Penalty Act of 1996, Snyder cannot obtain habeas relief unless he establishes that the state court's decision "was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States," or "resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding." 28 U.S.C. § 2254(d)(1)-(2). In other words, this Court will not evaluate Snyder's claim de novo. Rather, we analyze whether the Illinois Appellate Court's decision reasonably applied Supreme Court precedent to the facts of Snyder's case. A state court has reasonably applied Supreme Court case law if its application is "at least minimally consistent with the facts and circumstances of the case." Spreitzer v. Peters, 114 F.3d 1435, 1442 (7th Cir. 1997). Under this limited analysis, the state court's decision must stand "if it is one of several equally plausible outcomes." Hall v. Washington, 106 F.3d 742, 748-49 (7th Cir. 1997).


I. Procedural Default

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