Brandon Leon Bibbs v. Los Angeles Sheriff Dept.

CourtDistrict Court, C.D. California
DecidedMarch 23, 2021
Docket2:21-cv-02308
StatusUnknown

This text of Brandon Leon Bibbs v. Los Angeles Sheriff Dept. (Brandon Leon Bibbs v. Los Angeles Sheriff Dept.) 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. Los Angeles Sheriff Dept., (C.D. Cal. 2021).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES—GENERAL Case No. CV 21-2308-JVS (KK) Date: March 23, 2021 Title:

Present: The Honorable KENLY KIYA KATO, UNITED STATES MAGISTRATE JUDGE DEB TAYLOR Not Reported Deputy Clerk Court Reporter Attorney(s) Present for Petitioner(s): Attorney(s) Present for Respondent(s): None Present None Present

Proceedings: Order to Show Cause Why This Action Should Not Be Dismissed for Failure to (1) Name a Proper Respondent and (2) State a Cognizable Habeas Claim I. INTRODUCTION On March 10, 2021, Petitioner Brandon Leon Bibbs (“Bibbs”), who appears to be a detainee at Men’s Central Jail in Los Angeles, California, constructively filed1 a pro se Petition for Writ of Habeas Corpus (“Petition”) pursuant to 28 U.S.C. § 2254 (“Section 2255”). ECF Docket No. (“Dkt.”) 1. The Petition raises twelve claims, but does not appear to challenge any conviction. Id. As discussed below, the Court orders Bibbs to show cause why the Petition should not be dismissed for failure to (1) name a proper respondent and (2) state a cognizable habeas claim. /// /// /// /// /// /// /// 1 Under the “mailbox rule,” when a pro se prisoner gives prison authorities a pleading 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). II. DISCUSSION A. THE PETITION FAILS TO NAME A PROPER RESPONDENT 1. Applicable Law “[T]he proper respondent to a habeas petition is ‘the person who has custody over [the petitioner].’” Rumsfeld v. Padilla, 542 U.S. 426, 434 (2004) (citations omitted). Thus, “the default rule is that the proper respondent is the warden of the facility where the prisoner is being held[.]” Id. at 435; see also Stanley v. Cal. Sup. Ct., 21 F.3d 359, 360 (9th Cir. 1994) (as amended May 18, 1994) (holding the proper respondent in a habeas action is “typically . . . the warden of the facility in which the petitioner is incarcerated”); Brittingham v. United States, 982 F.2d 378, 379 (9th Cir. 1992) (per curiam). The Ninth Circuit has held that the “[f]ailure to name the correct respondent destroys personal jurisdiction.” Ortiz-Sandoval v. Gomez, 81 F.3d 891, 894 (9th Cir. 1996) (as amended May 8, 1996). 2. Analysis Here, the Petition names the “Los Angeles Sheriff Department” as the Respondent. See dkt. 1. The Los Angeles County Sheriff’s Department, however, is neither the person who has custody over Bibbs, nor the warden of the facility where Bibbs is being held. See Rumsfeld, 542 U.S. at 434- 35. Accordingly, the Petition is subject to dismissal for failure to name a proper respondent. See Sykes v. Los Angeles Sheriff’s Dep’t, No. CV 13-07409-VBK, 2015 WL 1285285, at *6 (C.D. Cal. Mar. 19, 2015) (holding petitioner failed to name a proper respondent because “Los Angeles County Sheriff Department, et al.” is not the individual state officer who has custody over petitioner). B. THE PETITION FAILS TO STATE A COGNIZABLE CLAIM 1. Applicable Law Under Section 2254, “a district court shall entertain an application for a writ of habeas corpus in behalf of a person in custody pursuant to the judgment of a State court only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a). “Challenges to the validity of any confinement or to particulars affecting its duration are the province of habeas corpus; requests for relief turning on circumstances of confinement may be presented in” an action filed pursuant to 42 U.S.C. § 1983 (“Section 1983”). Muhammad v. Close, 540 U.S. 749, 750 (2004) (citations omitted). Section 2254(a) uses the term “in custody” twice, with two different requirements. Bailey v. Hill, 599 F.3d 976, 978 (9th Cir. 2010). The first usage (i.e., that the petition be filed “in behalf of a person in custody”) requires that the petitioner is “under the conviction or sentence under attack at the time his petition is filed.” Id. at 978-79, 983 n.6 (quoting Resendiz v. Kovensky, 416 F.3d 952, 956 (9th Cir. 2005)). The second usage (i.e., that the application may be entertained “only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States”) requires “a nexus between the petitioner’s claim and the unlawful nature of the custody.” Id. at 978- 80. “[W]hen a prisoner’s claim would not necessarily spell speedier release, that claim does not lie at the core of habeas corpus and may be brought, if at all, under § 1983.” Skinner v. Switzer, 562 U.S. 521, 535 n.13 (2011) (internal quotation marks and citations omitted); see also Heck v. Humphrey, 512 U.S. 477, 481-83 (1994). 2. Analysis Here, the Petition does not appear to challenge any conviction. See dkt. 1. Rather, the Petition raises twelve claims that challenge various aspects of the conditions of Bibbs’ confinement, such as his access to the law library, exercise and recreation, courts and counsel, food, and showers. Id. at 2. The Petition, therefore, does not challenge the validity of Bibbs’ confinement or particulars affecting its duration. See Muhammad, 540 U.S. at 750. The Petition, instead, seeks relief turning on circumstances of confinement that may be presented, if at all, in an action filed pursuant to Section 1983.2 Id. Accordingly, the Petition is subject to dismissal for failure to state a cognizable habeas claim. III. ORDER For the above reasons, the Petition appears subject to dismissal. Bibbs is therefore ORDERED TO SHOW CAUSE why the Court should not dismiss the Petition for failure to (1) name a proper respondent and (2) state a cognizable claim. Bibbs’ response to this Order must be received no later than April 13, 2021. Bibbs must respond to this Order by (1) filing a request to amend the Petition to name the person who has custody over Bibbs (e.g., warden of Men’s Central Jail) AND (2) choosing one of the following options: 1. Option One: Bibbs may file a written response explaining why Bibbs’ claims are cognizable on habeas review. If Bibbs contends his claims are cognizable on habeas review, Bibbs must explain and attach any supporting documents. 2. Option Two: Bibbs may file a First Amended Petition curing the above referenced deficiencies. The First Amended Petition shall be complete in itself. It shall not refer in any manner to the original Petition. In other words, Bibbs must start over when preparing the First Amended Petition. If Bibbs chooses to file a First Amended Petition, he must clearly designate on the face of the document that it is the “First Amended Petition,” it must bear the docket number assigned to this case, and it must be retyped or rewritten in its entirety, preferably on the court-approved form. 2 When a prisoner’s claim is not cognizable in habeas corpus, the Court may construe the petition as a civil rights complaint. See Wilwording v.

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Related

Bailey v. Hill
599 F.3d 976 (Ninth Circuit, 2010)
WILWORDING Et Al. v. SWENSON, WARDEN
404 U.S. 249 (Supreme Court, 1971)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Muhammad v. Close
540 U.S. 749 (Supreme Court, 2004)
Rumsfeld v. Padilla
542 U.S. 426 (Supreme Court, 2004)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Roberts v. Marshall
627 F.3d 768 (Ninth Circuit, 2010)
Mark Brittingham v. United States
982 F.2d 378 (Ninth Circuit, 1992)
Jerry F. Stanley v. California Supreme Court
21 F.3d 359 (Ninth Circuit, 1994)
Ortiz-Sandoval v. Gomez
81 F.3d 891 (Ninth Circuit, 1996)
Skinner v. Switzer
179 L. Ed. 2d 233 (Supreme Court, 2011)

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Bluebook (online)
Brandon Leon Bibbs v. Los Angeles Sheriff Dept., Counsel Stack Legal Research, https://law.counselstack.com/opinion/brandon-leon-bibbs-v-los-angeles-sheriff-dept-cacd-2021.