Camacho v. Johnson

CourtDistrict Court, D. Nevada
DecidedAugust 10, 2023
Docket3:20-cv-00488
StatusUnknown

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

Bluebook
Camacho v. Johnson, (D. Nev. 2023).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3

4 MARIO CAMACHO, Case No. 3:20-cv-00488-RCJ-CSD 5 Petitioner, 6 ORDER v. 7 CALVIN JOHNSON, et al., 8 Respondents. 9

10 11 12 On July 28, 2022, the petitioner in this habeas corpus action, Mario Camacho, 13 represented by appointed counsel, filed a motion for stay, requesting that the case be 14 stayed while he exhausts in state court the claims in Grounds 5A through 5H of his 15 second amended habeas petition (ECF No. 58). Determining that the claims Camacho 16 wished to present in state court appeared to be procedurally barred—Camacho 17 conceded as much in his second amended habeas petition (Second Amended Petition 18 (ECF No. 35), p. 25)—and that Camacho did not claim he could overcome the 19 procedural bars under current Nevada law, the Court denied the motion for stay on 20 August 31, 2022. See Order entered August 31, 2022 (ECF No. 62). 21 On May 11, 2023, Camacho filed a motion for reconsideration (ECF No. 72), 22 requesting reconsideration of the order denying his motion for stay. Camacho now 23 shows that the circumstances have changed: the state district court has granted 24 Camacho an evidentiary hearing. As it now appears that Camacho may be able to 25 overcome the procedural bars of his claims in state court, and/or that he may be able to 26 develop new evidence related to his claims, the Court will grant the motion for 27 reconsideration, and will stay this case pending the conclusion of the state habeas 1 A district court “possesses the inherent procedural power to reconsider, rescind, 2 or modify an interlocutory order for cause seen by it to be sufficient[,]” so long as it has 3 jurisdiction. City of Los Angeles, Harbor Div. v. Santa Monica Baykeeper, 254 F.3d 882, 4 885 (9th Cir. 2001) (quotation and emphasis omitted); see also Smith v. Clark Cty. Sch. 5 Dist., 727 F.3d 950, 955 (9th Cir. 2013); Local Rule (LR) 59-1. A motion to reconsider 6 must set forth “some valid reason why the court should reconsider its prior decision” by 7 presenting “facts or law of a strongly convincing nature.” Frasure v. United States, 256 8 F. Supp. 2d 1180, 1183 (D. Nev. 2003). Here, a significant change in circumstances 9 warrants reconsideration of the order denying Camacho’s motion for stay. 10 A federal court may not grant relief on a habeas corpus claim not exhausted in 11 state court. 28 U.S.C. § 2254(b). The Supreme Court has recognized that under certain 12 circumstances it may be appropriate for a federal court to anticipate a state-law 13 procedural bar of an unexhausted claim, and to treat such a claim as subject to the 14 procedural default doctrine. “An unexhausted claim will be procedurally defaulted, if 15 state procedural rules would now bar the petitioner from bringing the claim in state 16 court.” Dickens v. Ryan, 740 F.3d 1302, 1317 (9th Cir. 2014) (citing Coleman v. 17 Thompson, 501 U.S. 722, 731 (1991)). 18 Regarding the effect of a procedural default, in Coleman v. Thompson, 501 U.S. 19 722 (1991), the Supreme Court held that a state prisoner who fails to comply with state- 20 law procedural requirements in presenting his claims in state court is barred by the 21 adequate and independent state ground doctrine from obtaining a writ of habeas corpus 22 in federal court. Coleman, 501 U.S. at 731–32 (“Just as in those cases in which a state 23 prisoner fails to exhaust state remedies, a habeas petitioner who has failed to meet the 24 State’s procedural requirements for presenting his federal claims has deprived the state 25 courts of an opportunity to address those claims in the first instance.”). Where such a 26 procedural default constitutes an adequate and independent state ground for denial of 27 habeas corpus, the default may be excused only if “a constitutional violation has 1 demonstrates cause for the default and prejudice resulting from it. Murray v. Carrier, 2 477 U.S. 478, 496 (1986). 3 Turning to the legal standard governing a motion for an exhaustion stay, a district 4 court is authorized to stay a habeas action in “limited circumstances” while a petitioner 5 presents unexhausted claims to the state court. Rhines v. Weber, 544 U.S. 269, 273–75 6 (2005). Under Rhines, “a district court must stay a mixed petition only if: (1) the 7 petitioner has ‘good cause’ for his failure to exhaust his claims in state court; (2) the 8 unexhausted claims are potentially meritorious; and (3) there is no indication that the 9 petitioner intentionally engaged in dilatory litigation tactics.” Wooten v. Kirkland, 540 10 F.3d 1019, 1023 (9th Cir. 2008) (citing Rhines, 544 U.S. at 278). Ineffective assistance 11 of postconviction counsel or a lack of postconviction counsel can constitute good cause 12 under Rhines. See Blake v. Baker, 745 F.3d 977, 982–83 (9th Cir. 2014); Dixon v. 13 Baker, 847 F.3d 714, 721 (9th Cir. 2017). But courts “must interpret whether a petitioner 14 has ‘good cause’ for a failure to exhaust in light of the Supreme Court's instruction in 15 Rhines that the district court should only stay mixed petitions in ‘limited circumstances.’” 16 Wooten, 540 F.3d at 1024 (citing Jackson v. Roe, 425 F.3d 654, 661 (9th Cir. 2005)). 17 Courts must also be “mindful that AEDPA aims to encourage the finality of sentences 18 and to encourage petitioners to exhaust their claims in state court before filing in federal 19 court.” Id. (citing Rhines, 544 U.S. at 276–77). 20 In response to Camacho’s motion for stay, Respondents contended that a stay is 21 inappropriate because a new state habeas petition asserting the claims in Grounds 5A 22 through 5H would be procedurally barred. See Opposition to Motion for Stay (ECF No. 23 59). Respondents contended that Camacho’ return to state court to file an untimely and 24 successive state habeas petition would be futile. See id. In essence, Respondents 25 contended that the claims in Grounds 5A through 5H are not unexhausted, but, rather, 26 are technically exhausted but subject to application of the procedural default doctrine. 27 See id. Indeed, in his second amended habeas petition, Camacho represented that his 1 See Second Amended Petition for Writ of Habeas Corpus (ECF No. 35), p. 25. And, in 2 his motion for stay, Camacho made no argument that he could overcome the state-law 3 procedural bars of the claims in Grounds 5A through 5H under current Nevada law. 4 Based on the record and the representations of the parties, then, the Court denied 5 Camacho’s motion for stay. The Court stated:

6 The point of a Rhines stay is to allow a federal habeas petitioner an opportunity to present unexhausted claims in state court. But here, the 7 claims in Grounds 5A through 5H are not unexhausted. It is undisputed that those claims are procedurally barred in state court, and Camacho 8 makes no argument that he can overcome the procedural bars under current Nevada law. Therefore, the Court finds that the claims in Grounds 9 5A through 5H are technically exhausted but subject to application of the procedural default doctrine.

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Related

Murray v. Carrier
477 U.S. 478 (Supreme Court, 1986)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Fred Jay Jackson v. Ernest C. Roe, Warden
425 F.3d 654 (Ninth Circuit, 2005)
Jacqlyn Smith v. Clark County School District
727 F.3d 950 (Ninth Circuit, 2013)
Mason Motors Co. v. United States
8 F. Supp. 2d 1177 (D. Minnesota, 1998)
Gregory Dickens v. Charles L. Ryan
740 F.3d 1302 (Ninth Circuit, 2014)
Alfonso Blake v. Renee Baker
745 F.3d 977 (Ninth Circuit, 2014)
Terry Dixon v. Renee Baker
847 F.3d 714 (Ninth Circuit, 2017)

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Camacho v. Johnson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/camacho-v-johnson-nvd-2023.