Beal v. District Attorney Alameda

CourtDistrict Court, N.D. California
DecidedSeptember 3, 2025
Docket3:24-cv-03660
StatusUnknown

This text of Beal v. District Attorney Alameda (Beal v. District Attorney Alameda) 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
Beal v. District Attorney Alameda, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 CHARLES CLIFTON BEAL, Case No. 24-cv-03660-AMO (PR)

8 Petitioner, ORDER GRANTING RESPONDENT’S MOTION TO DISMISS; DENYING 9 v. CERTIFICATE OF APPEALABILITY; AND DENYING AS MOOT ALL 10 JASON SCHULTZ, Warden,1 REMAINING PENDING MOTIONS 11 Respondent. Re: Dkt. No. 19, 22, 23, 24, 25, 28, 29, 31

12 I. INTRODUCTION 13 Petitioner Charles Clifton Beal, a state prisoner currently incarcerated at California State 14 Prison - Sacramento, filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254, 15 representing himself. Dkt. 1. Thereafter, the Court issued an order to show cause. Dkt. 17. 16 Before the Court is Respondent’s motion to dismiss the instant petition without prejudice 17 due to ongoing state court proceedings. Dkt. 22. Beal opposes the motion and has filed numerous 18 pending motions. Dkts. 19, 23, 24, 25, 28, 29, 31. Respondent has filed a reply. Dkt. 26 19 Having considered all of the papers filed by the parties, the Court GRANTS Respondent’s 20 motion to dismiss the petition, and DENIES as moot all of Beal’s remaining pending motions. 21 II. BACKGROUND 22 On October 30, 2023, an Alameda County jury found Beal guilty of first degree murder 23 and possession of a firearm by a felon. Resp’t Ex. 1, Clerk’s Transcript (“CT”) 245-246. The jury 24 also found true, with respect to the murder, enhancements for personal use of a firearm and 25 personal infliction of great bodily injury. CT 245-246. On January 10, 2024, the California Court of Appeal dismissed Beal’s premature appeal because he had not yet been sentenced. CT 335. On 26 27 1 February 27, 2024, the state court found Beal had been convicted of several prior offenses, 2 including a prior strike conviction. CT 338-339. On March 20, 2024, the trial court sentenced 3 him to sixty years to life in state prison. CT 369. Beal appealed and filed his opening brief on 4 February 20, 2025. Resp’t Reply Ex. 1 at 5-51. 5 Beal has also sought collateral review in state court as evidenced by his notice and request 6 for ruling on a petition for writ of habeas corpus pending in San Francisco County Superior Court. 7 Dkt. 23 at 4. To date, neither party has updated the Court as to the status of Beal’s state superior 8 court habeas petition. Furthermore, according to its online database, Beal has also filed a state 9 habeas petition in the California Supreme Court on June 4, 2025. See Beal (Charles Clifton) on 10 H.C., Case No. S291322 (June 4, 2025). Beal’s state habeas petition remains pending there. See 11 id. On May 31, 2024, the present petition was received by the Ninth Circuit Court of Appeals. 12 Dkt. 1. On June 14, 2024, the Ninth Circuit issued an order transferring the matter to this Court. 13 Dkt. 2. On January 2, 2025, the Court issued an order to show cause. Dkt. 17. 14 DISCUSSION 15 Respondent argues that the Court must dismiss this petition in keeping with Younger 16 abstention. Younger abstention requires that, under principles of comity and federalism, a federal 17 court should not interfere with ongoing state criminal proceedings by granting injunctive or 18 declaratory relief absent extraordinary circumstances. See Younger v. Harris, 401 U.S. 37, 43-54 19 (1971); Samuels v. Mackell, 401 U.S. 66, 68-74 (1971). Younger abstention is mandated when: 20 (1) state proceedings, judicial in nature, are pending; (2) the state proceedings involve important 21 state interests; and (3) the state proceedings afford adequate opportunity to raise the constitutional 22 issue. See Middlesex County Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 432 (1982). 23 The Ninth Circuit also requires that “the federal court action would enjoin the proceeding or have 24 the practical effect of doing so, i.e., would interfere with the state proceeding in a way that 25 Younger disapproves.” SJSVCCPAC v. City of San Jose, 546 F.3d 1087, 1092 (9th Cir. 2008) 26 (citing cases). 27 1 is currently pending. Dkt. 22 at 2-4; Dkt. 26 at 2-3. Respondent specifically argues that Beal 2 “must exhaust his claims in state court before the federal court can grant habeas relief.” Dkt. 26 3 at 2 (citing 28 U.S.C. § 2254(b)(1)). The Court agrees that Younger abstention is appropriate here. 4 First, state proceedings are ongoing, as they were initiated before any proceedings of 5 substance on the merits have taken place in federal court. See Nationwide Biweekly 6 Administration, Inc. v. Owen, 873 F.3d 716, 728 (9th Cir. 2017). Beal initiated a separate state 7 proceeding when he appealed his conviction in state court and filed his state habeas petition in the 8 California Supreme Court. Those state proceedings remain pending. As Respondent correctly 9 notes, the rationale of Younger applies throughout appellate proceedings, requiring that state 10 appellate review of a state court judgment be exhausted before federal court intervention is 11 permitted. See Huffman v. Pursue, Ltd., 420 U.S. 592, 607-11 (1975) (holding that Younger 12 abstention applies to prevent federal intervention in state judicial proceeding in which losing 13 litigant has not yet exhausted his state appellate remedies); see also Dubinka v. Judges of the Sup. 14 Ct., 23 F.3d 218, 223 (9th Cir. 1994) (finding that even if criminal trials were completed at time of 15 abstention decision, state court proceedings still considered pending). 16 Second, state criminal proceedings implicate important state interests. See Kelly v. 17 Robinson, 479 U.S. 36, 49 (1986) (noting that the Court has recognized that the “the States’ 18 interest in administering their criminal justice systems free from federal interference is one of the 19 most powerful of the considerations that should influence a court considering equitable types of 20 relief”). 21 Third, the state proceedings afford Beal adequate opportunity to raise the constitutional 22 issues in that he is not precluded from raising the same challenges that he has raised here. 23 Finally, the practical effect of granting habeas relief in this action would interfere with the 24 ongoing state court proceedings in that it would imply the invalidity of the conviction and require 25 this Court to make findings about whether the underlying trial violated Beal’s constitutional rights. 26 Because Younger abstention is appropriate, Respondent’s motion to dismiss the instant 27 petition due to ongoing state court proceedings is GRANTED. Dkt. 22. The dismissal is without WI. CERTIFICATE OF APPEALABILITY The Court concludes that no “jurists of reason would find it debatable whether the petition states a valid claim of the denial of a constitutional right [or] that jurists of reason would find it ° debatable whether the district court was correct in its procedural ruling.” Slack v. McDaniel, 529 U.S. 473, 484 (2000). Accordingly, a certificate of appealability is DENIED. IV.

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Huffman v. Pursue, Ltd.
420 U.S. 592 (Supreme Court, 1975)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Nationwide Biweekly Administration, Inc. v. Owen
873 F.3d 716 (Ninth Circuit, 2017)

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Beal v. District Attorney Alameda, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beal-v-district-attorney-alameda-cand-2025.