Brandon Leon Bibbs v. Alex Villanueva

CourtDistrict Court, C.D. California
DecidedOctober 1, 2020
Docket2:20-cv-08728
StatusUnknown

This text of Brandon Leon Bibbs v. Alex Villanueva (Brandon Leon Bibbs v. Alex Villanueva) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brandon Leon Bibbs v. Alex Villanueva, (C.D. Cal. 2020).

Opinion

1 2

4 5 6 UNITED STATES DISTRICT COURT 7 CENTRAL DISTRICT OF CALIFORNIA 8

9 10 BRANDON LEON BIBBS, Case No. CV 20-8728-JVS (KK) 11 Petitioner, ORDER SUMMARILY DISMISSING ACTION WITH PREJUDICE 12 v.

13 ALEX VILLANUEVA,

14 Respondent.

15 16 17 I. 18 INTRODUCTION 19 Pro se petitioner Brandon Leon Bibbs (“Petitioner”), a pretrial detainee 20 currently confined at Men’s Central Jail in Los Angeles County, filed a Petition for 21 Writ of Habeas Corpus by a Person in State Custody (“Petition”). ECF Docket No. 22 (“Dkt.”) 1. For the reasons discussed below, the Court summarily DISMISSES this 23 action with prejudice. 24 /// 25 /// 26 /// 27 /// 1 II. 2 BACKGROUND 3 A. PREVIOUS PETITION IN CV 20-4222-JVS (KK) 4 On May 28, 2020, Petitioner constructively filed1 a First Amended Petition in 5 this Court in Case No. CV 20-4222-JVS (KK). Bibbs v. United States, CV 20-4222- 6 JVS (KK), Dkt. 8, FAP. Petitioner alleged he is “currently in custody of the Los 7 Angeles Sheriff’s Department, charged with 10 counts of robbery with a firearm, by 8 information, awaiting trial in the Superior Court of Los Angeles (Super Ct. Case no. 9 VA134204).” Id. at 2. Petitioner named Sherriff Alex Villanueva as respondent and 10 sought “emergency temporary release” pursuant to “U.S. v. Daniels, 2020 U.S. Dist. 11 LEXIS 63365”, Section 2241, and the First, Sixth, Eighth, and Fourteenth 12 Amendments, based on the following claims: (1) “L.A. County Jail[’s] overpopulation 13 with COVID-19 patients”; (2) “unsanitary jail conditions”; (3) “inadequacy of courts 14 and counsel”; and (4) “safe release conditions.” Id. at 1. Petitioner appeared to argue 15 the “extraordinary circumstances” exception to Younger2 was warranted based on 16 “the hinderance of courts and counsel, that he is horrified by unsanitary jail 17 conditions in furtherance to the uprising global pandemic, stemming to possible 18 sudden death or delay . . . .” Id. at 2. 19 On July 17, 2020, the Court summarily dismissed the action with prejudice 20 because federal court abstention was required pursuant to Younger and entered 21 Judgment accordingly. Dkts. 11, 12. 22 B. CURRENT PETITION 23 On September 15, 2020, Petitioner filed the instant Petition again challenging 24 his pretrial detention by the Los Angeles Sheriff’s Department pending trial in Los 25 Angeles County Superior Court Case No. VA134204. Dkt. 1 at 2-3. Petitioner sets 26 1 Under the “mailbox rule,” when a pro se prisoner gives prison authorities a pleading 27 to mail to court, the court deems the pleading constructively “filed” on the date it is signed. Roberts v. Marshall, 627 F.3d 768, 770 n.1 (9th Cir. 2010) (citation omitted). 1 forth the following two claims for relief: (1) Petitioner was “illegally committed” in 2 violation of the Fourth, Fifth, Sixth, and Fourteenth Amendments when he was 3 arraigned on May 31, 2016 without a “filed felony complaint”, an unverified second 4 amended felony complaint was filed on December 13, 2016, he was held to answer 5 without an endorsed order on January 17, 2017, and the prosecution filed an 6 information charging him on January 31, 2017; and (2) Petitioner was “illegally 7 arrested” in violation of the Fourth and Fourteenth Amendments when he was 8 “brought to custody in the Los Angele Sheriff’s Department” on April 22, 2016 9 without an arrest report or information. Id. at 5-6. 10 III. 11 DISCUSSION 12 THE PETITION IS SUBJECT TO DISMISSAL BECAUSE IT SEEKS TO 13 INTERFERE WITH PENDING STATE COURT PROCEEDINGS 14 A. APPLICABLE LAW 15 When a state prisoner “is challenging the very fact or duration of his physical 16 imprisonment, and the relief he seeks is a determination that he is entitled to 17 immediate release or a speedier release from that imprisonment, his sole federal 18 remedy is a writ of habeas corpus”. Preiser v. Rodriguez, 411 U.S. 475, 500, 93 S. Ct. 19 1827, 1841, 36 L. Ed. 2d 439 (1973). “[T]he general grant of habeas authority in [28 20 U.S.C. § 2241] is available for challenges by a state prisoner who is not in custody 21 pursuant to a state court judgment [such as] a defendant in pre-trial detention[.]” 22 Stow v. Murashige, 389 F.3d 880, 886 (9th Cir. 2004) (quoting White v. Lambert, 370 23 F.3d 1002, 1006 (9th Cir. 2004)) (holding pretrial detainee’s request for federal habeas 24 relief under 28 U.S.C. § 2241(c)(3) is properly brought); Rosenbalm v. Mendocino 25 Superior Court, No. C 06-7412 SI(PR), 2007 WL 878522, at *1 (N.D. Cal. Mar. 21, 26 2007) (“This court may entertain a petition for a writ of habeas corpus under 28 27 U.S.C. § 2241(c)(3) by a person who is in custody but not yet convicted or 1 Principles of comity and federalism, however, require federal courts to abstain 2 from interfering with pending state court proceedings. See Younger v. Harris, 401 3 U.S. 37, 43-45, 91 S. Ct. 746, 27 L. Ed. 2d 669 (1971). The Ninth Circuit has held 4 abstention is appropriate when: (1) there is “an ongoing state judicial proceeding”; (2) 5 the proceeding “implicate[s] important state interests”; (3) there is “an adequate 6 opportunity in the state proceedings to raise constitutional challenges”; and (4) the 7 requested relief “seek[s] to enjoin” or has “the practical effect of enjoining” the 8 ongoing state judicial proceeding. Arevalo v. Hennessy, 882 F.3d 763, 765 (9th Cir. 9 2018) (citing ReadyLink Healthcare, Inc. v. State Comp. Ins. Fund, 754 F.3d 754, 758 10 (9th Cir. 2014)). 11 “Extraordinary circumstances,” may warrant exception to the “fundamental 12 policy against federal interference with state criminal prosecutions.” Younger, 401 13 U.S. at 46, 53-54; Brown v. Ahern, 676 F.3d 899, 900-01 (9th Cir. 2012) (holding 14 “abstention principles . . . prohibit a federal court from considering a pre-conviction 15 habeas petition that seeks preemptively to litigate an affirmative constitutional defense 16 unless the petitioner can demonstrate that ‘extraordinary circumstances’ warrant 17 federal intervention.” (citing Carden v. State of Mont., 626 F.2d 82, 83 (9th Cir. 18 1980))). To demonstrate an exception to Younger, a petitioner must show: (1) he 19 would suffer irreparable harm that is “both great and immediate” if the federal court 20 declines jurisdiction; (2) there is bad faith or harassment, on the part of state, in 21 prosecuting him; or (3) the state court system is biased against Petitioner’s federal 22 claim. See Middlesex County Ethics Comm’n v. Garden State Bar Ass’n, 457 U.S. 23 423, 432, 102 S. Ct. 2515, 73 L. Ed. 2d 116 (1982); Kugler v. Helfant, 421 U.S. 117, 24 124-25, 95 S. Ct. 1524, 44 L. Ed. 2d 15 (1975); see also Brown, 676 F.3d at 901 (citing 25 Carden, 626 F.2d at 83). 26 /// 27 /// 1 B. ANALYSIS 2 As an initial matter, Petitioner admits his criminal case is “still pending” in the 3 Los Angeles County Superior Court. Dkt. 1 at 2-3. Petitioner is, therefore, a pretrial 4 detainee. Accordingly, 28 U.S.C.

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Kugler v. Helfant
421 U.S. 117 (Supreme Court, 1975)
Kelly v. Robinson
479 U.S. 36 (Supreme Court, 1986)
Roberts v. Marshall
627 F.3d 768 (Ninth Circuit, 2010)
Brown v. Ahern
676 F.3d 899 (Ninth Circuit, 2012)
Steven Donald Stow v. Albert Murashige
389 F.3d 880 (Ninth Circuit, 2004)
Bingham v. Cabbot
3 U.S. 19 (Supreme Court, 1795)
Villalta-Martinez v. Sessions
882 F.3d 20 (First Circuit, 2018)
Erick Arevalo v. Vicki Hennessy
882 F.3d 763 (Ninth Circuit, 2018)

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Brandon Leon Bibbs v. Alex Villanueva, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brandon-leon-bibbs-v-alex-villanueva-cacd-2020.