Al Khafaji v. Koenig

CourtDistrict Court, N.D. California
DecidedDecember 28, 2021
Docket4:20-cv-06815
StatusUnknown

This text of Al Khafaji v. Koenig (Al Khafaji v. Koenig) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Al Khafaji v. Koenig, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 HAYDAR AL-KHAFAJI, Case No. 20-cv-06815-JST

8 Petitioner, ORDER OF DISMISSAL v. 9

10 CRAIG KOENIG, Respondent. 11

12 13 Petitioner, a state prisoner incarcerated at Correctional Training Facility, has filed a pro se 14 petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254 challenging an August 15, 2019 15 denial of parole. For the reasons set forth below, the petition is DISMISSED. 16 DISCUSSION 17 I. State Court Proceedings 18 On December 6, 2009, Petitioner was convicted in San Diego Superior Court of 19 kidnapping for rape, assault with intent to commit rape, and robbery (Cal. Penal Code 20 §§ 209(b)(1), 220(a), 211). ECF No. 6 at 9. Petitioner was sentenced to life with the possibility of 21 parole, plus three years. ECF No. 6 at 9. 22 On August 15, 2019, the Board of Parole Hearings (“BPH”) found Petitioner unsuitable for 23 parole at that time. ECF No. 6 at 9. 24 On or about November 26, 2019, Petitioner filed a state habeas petition in the San Diego 25 County Superior Court, arguing that the BPH abused its discretion in finding him unsuitable for 26 parole because the BPH relied on an outdated 2017 psychiatric report despite the fact that 27 Petitioner’s current psychologist could have provided an updated report that would have refuted 1 marijuana in a decade; concluded that Petitioner did not present realistic plans for substance abuse 2 and mental health treatment despite Petitioner presenting information showing that a professor had 3 agreed to counsel him and Petitioner would have been subject to the state parole office’s 4 psychiatric outpatient clinic. ECF No. 7-3 at 24-28. The state superior court denied the petition, 5 finding that the BPH’s decision was supported by some evidence and finding that Petitioner’s 6 arguments were unpersuasive. ECF No. 7-3 at 24-28. 7 Petitioner filed a habeas petition with the California Court of Appeals, arguing that the 8 BPH violated his federal and state due process rights because its unsuitability finding was based 9 on giving too much weight to his mental illness and substance abuse, relying on an outdated 10 psychological evaluation, and not giving enough weight to his good behavior and self- 11 improvement efforts in prison and his plans for release on parole. ECF No. 7-3 at 34-36. On 12 March 6, 2020, the state appellate court denied the petition, finding that the BPH conducted the 13 required individualized consideration of the specified criteria, that the BPH’s suitability decision 14 was supported by some evidence, and that the decision was neither arbitrary nor procedurally 15 flawed. ECF No. 7-3 at 34-36. 16 On March 30, 2020, Petitioner filed a habeas petition with the California Supreme Court, 17 challenging the BPH’s August 15, 2019 unsuitability finding. Petitioner argued that the BPH 18 abused its discretion in the following ways: (1) the BPH commissioner referred to him as a person 19 who has a problem with women; (2) the BPH commissioner conspired to have a female district 20 attorney falsely convey non-existent reports from the victim; (3) the BPH commissioner 21 “showboated” in the presence of the female deputy commissioner, the female district attorney, the 22 female trainee, and Petitioner’s female attorney by badgering Petitioner as to whether Petitioner’s 23 professor was aware that Petitioner had a problem with women, was mentally ill, and posed a 24 threat to public safety; (4) the BPH commissioner relied on an outdated psychiatric report and its 25 own misplaced interpretation of Petitioner’s current mental status; and (5) the BPH commissioner 26 repeatedly emphasized that Petitioner was mentally unstable as the sole reason to deny parole. 27 The only legal claim made in this petition was that the parole denial violated Petitioner’s federal 1 was evidence of his parole suitability; because he could continue receiving psychiatric treatment 2 through his parole office; and because the BPH commissioner misstated/misunderstood the facts 3 of the underlying crime. ECF No. 6 at 9-27. On July 8. 2020, the California Supreme Court 4 denied the state habeas petition. 5 On or about September 29, 2020, Petitioner filed the instant federal petition for a writ of 6 habeas corpus by submitting the petition he filed with the California Supreme Court. ECF No. 6. 7 On March 15, 2021, the Court screened the instant petition and found that the petition 8 made the following due process claim: a BPH commissioner abused his discretion and violated the 9 federal Due Process Clause and California caselaw when he found Petitioner unsuitable for parole 10 by relying on an outdated mental health assessment and by considering substance abuse and 11 mental health issues. ECF No. 16. The Court found that this allegation failed to state a cognizable 12 federal habeas claim because the Supreme Court has held that federal courts may not intervene in 13 parole decisions as long as the minimum procedural protections – the opportunity to be heard and 14 a statement of the reasons why parole was denied – are provided and because the Due Process 15 Clause does not require correct application of California’s “some evidence” standard for denial of 16 parole. ECF No. 16 at 2-3 (citing Swarthout v. Cooke, 562 U.S. 216, 220-21 (2011) and Roberts 17 v. Hartley, 640 F.3d 1042, 1046 (9th Cir. 2011)). The Court ordered Petitioner to show cause why 18 this petition should not be dismissed for failure to state a cognizable federal habeas claim. ECF 19 No. 16. 20 II. Response to Order to Show Cause 21 In his response to the Order to Show Cause, Petitioner does not deny that he received the 22 necessary procedural protections required by the federal Due Process Clause.1 Rather, he now 23 argues that the parole board was biased as follows:

24 Plaintiff never had a fair hearing at his parole board all the women were obviously biased in their comments “So you have a problem 25 with women?” 26

27 1 Petitioner was present at the hearing and was provided a statement of the reasons why parole was 1 ECF No. 17 at 6. 2 A prisoner is entitled to have his release date considered by a parole board that is free from 3 bias or prejudice. O’Bremski v. Maas, 915 F.2d 418, 422 (9th Cir. 1990) (citing Schweiker v. 4 McClure, 456 U.S. 188, 195 (1982); Morrissey v. Brewer, 408 U.S. 471, 489 (1972); and Sellars 5 v. Procunier, 641 F.2d 1295, 1303 (9th Cir. 1981)). “[B]ecause parole board officials perform 6 tasks that are functionally comparable to those performed by the judiciary, they owe the same 7 duty: ‘to render impartial decisions in cases and controversies that excite strong feelings because 8 the litigant’s liberty is at stake.’” O’Bremski, 915 F.3d at 422 (citing Sellars, 641 F.2d at 1303). 9 However, Petitioner’s allegation that the single question “So you have a problem with 10 women?” indicates that the decision was biased is too conclusory to present a cognizable claim of 11 biased decision-making.2 Also, even if this allegation were sufficient to state a cognizable claim 12 for federal habeas relief, this claim was not raised in the instant federal petition.

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Related

Morrissey v. Brewer
408 U.S. 471 (Supreme Court, 1972)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Schweiker v. McClure
456 U.S. 188 (Supreme Court, 1982)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Roberts v. Hartley
640 F.3d 1042 (Ninth Circuit, 2011)
John Houston Sellars v. Raymond K. Procunier
641 F.2d 1295 (Ninth Circuit, 1981)
Swarthout v. Cooke
178 L. Ed. 2d 732 (Supreme Court, 2011)

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Al Khafaji v. Koenig, Counsel Stack Legal Research, https://law.counselstack.com/opinion/al-khafaji-v-koenig-cand-2021.