Stephen Christian, A/K/A Stephen Cline v. William Rhode

The cry, “There’s gold in them thar hills!” has long lured investors, dreamers, and sometimes deceivers. So it did in this case. Arizona investors laid out over $1.8 million to obtain interests in mining operations, only to discover that there was neither gold nor any hills. The mines were nonexistent, the shares worthless, and the mine promoter, Stephen Christian, and his cohorts had spent the invested funds on personal effects.

Christian was convicted on multiple counts of criminal fraud, conspiracy, and theft by an Arizona jury. After exhausting state remedies, Christian petitioned pro se for a writ of habeas corpus. The district court denied the petition. Christian appeals, arguing that (1) the state’s use of videotaped depositions violated his Sixth Amendment right to confront witnesses, (2) his appointed counsel was ineffective for failing to object to the deposition procedure, (3) the district court improperly enhanced his sentence, and (4) the district court improperly denied his discovery motion. We affirm the district court’s denial of the writ.

I.

Christian created several purported mining companies and NQUIR Financials Ltd. (NQUIR), a Cayman Islands corporation…