Carlos Alfonso Bolanos v. Luis Garnica

CourtDistrict Court, E.D. California
DecidedFebruary 2, 2026
Docket1:25-cv-00585
StatusUnknown

This text of Carlos Alfonso Bolanos v. Luis Garnica (Carlos Alfonso Bolanos v. Luis Garnica) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carlos Alfonso Bolanos v. Luis Garnica, (E.D. Cal. 2026).

Opinion

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10

11 CARLOS ALFONSO BOLANOS, Case No. 1:25-cv-00585-KES-EPG-HC

12 Petitioner, FINDINGS AND RECOMMENDATION TO GRANT RESPONDENT’S MOTION TO 13 v. DISMISS AND DISMISS FIRST AMENDED PETITION FOR WRIT OF HABEAS 14 LUIS GARNICA,1 CORPUS WITHOUT PREJUDICE

15 Respondent. (ECF Nos. 7, 11)

16 ORDER DIRECTING CLERK OF COURT TO SUBSTITUTE RESPONDENT 17 18 Petitioner Carlos Alfonso Bolanos is a state prisoner proceeding pro se with a petition for 19 writ of habeas corpus pursuant to 28 U.S.C. § 2254. For the reasons stated herein, the 20 undersigned recommends granting Respondent’s motion to dismiss and dismissing the first 21 amended petition without prejudice based on Younger v. Harris, 401 U.S. 37 (1971). 22 I. 23 BACKGROUND 24 Petitioner was convicted of various sex crimes for which he was sentenced to serve 25 multiple terms of life in prison without parole and multiple terms of life in prison with parole. 26

27 1 Luis Garnica is the warden of Mule Creek State Prison, where Petitioner is currently housed. (ECF No. 11 at 1 n.1.) Accordingly, Luis Garnica is substituted as Respondent in this matter. See Ortiz-Sandoval v. 1 (LDs2 1, 2.) On January 26, 2023, the California Court of Appeal, Fifth Appellate District 2 reversed the judgment on count 8, vacated the terms imposed on counts 4, 5, 6, and 7, and 3 directed the trial court to enter judgment of acquittal on count 8 and pronounce judgment on 4 counts 4, 5, 6, and 7 consistent with the opinion. The judgment was otherwise affirmed. (LD 2.) 5 The California Supreme Court granted Petitioner’s petition for review and on January 22, 2025, 6 transferred the matter to the California Court of Appeal “with directions to vacate its decision 7 and reconsider the cause in light of In re Vaquera (2024) 15 Cal.5th 706.” (LD 4.) On March 24, 8 2025, the California Court of Appeal issued a second opinion with the same disposition. (LD 5.) 9 A sentencing hearing was scheduled in the Madera County Superior Court for September 5, 10 2025, (LD 6), and it was rescheduled to October 31, 2025, (ECF No. 11 at 23). 11 On May 19, 2025, Petitioner filed a petition for writ of habeas corpus in this Court. (ECF 12 No. 1.) The Court granted Petitioner leave to amend the petition, and on August 27, 2025, 13 Petitioner filed a first amended petition (“FAP”). (ECF Nos. 6, 7.) On October 24, 2025, 14 Respondent filed a motion to dismiss the petition on abstention grounds. (ECF No. 11.) To date, 15 no opposition or statement of non-opposition has been filed, and the time for doing so has 16 passed. 17 II. 18 DISCUSSION 19 In Younger v. Harris, the Supreme Court held that when there is a pending state criminal 20 proceeding, federal courts must refrain from enjoining the state prosecution absent special or 21 extraordinary circumstances. 401 U.S. at 45. 22 We have articulated a four-part test to determine when Younger requires that federal courts abstain from adjudicating cases that 23 would enjoin or risk interfering with pending state-court proceedings. “Younger abstention is appropriate when: (1) there is 24 ‘an ongoing state judicial proceeding’; (2) the proceeding ‘implicate[s] important state interests’; (3) there is ‘an adequate 25 opportunity in the state proceedings to raise constitutional challenges’; and (4) the requested relief ‘seek[s] to enjoin’ or has 26 ‘the practical effect of enjoining’ the ongoing state judicial 27 2 “LD” refers to the documents lodged by Respondent. (ECF No. 12.) 1 proceeding.” Arevalo v. Hennessy, 882 F.3d 763, 765 (9th Cir. 2018) (alterations in original) (quoting ReadyLink Healthcare, Inc. 2 v. State Compensation Ins. Fund, 754 F.3d 754, 758 (9th Cir. 2014)). 3 4 Duke v. Gastelo, 64 F.4th 1088, 1094 (9th Cir. 2023). “Abstention is only appropriate when all 5 four requirements are met.” Id. The Court “must conduct the Younger analysis in light of the 6 facts and circumstances existing at the time the federal action was filed.” Id. at 1093 (internal 7 quotation marks and citations omitted). 8 “But even where the Younger factors are satisfied, ‘federal courts do not invoke it if there 9 is a showing of bad faith, harassment, or some other extraordinary circumstance that would make 10 abstention inappropriate.’” Bean v. Matteucci, 986 F.3d 1128, 1133 (9th Cir. 2021) (some 11 internal quotation marks omitted) (quoting Arevalo v. Hennessy, 882 F.3d 763, 765–66 (9th Cir. 12 2018)). Extraordinary circumstances include “cases of proven harassment or prosecutions 13 undertaken by state officials in bad faith without hope of obtaining a valid conviction,” or 14 situations “where irreparable injury can be shown.” Brown v. Ahern, 676 F.3d 899, 903 (9th Cir. 15 2012) (internal quotation marks omitted) (quoting Carden v. Montana, 626 F.2d 82, 84 (9th Cir. 16 1980)). 17 The question of whether a federal court should abstain from exercising jurisdiction over a 18 habeas petition challenging a conviction when there is no final decision regarding the sentence 19 has been addressed in Phillips v. Vasquez, 56 F.3d 1030 (9th Cir. 1995), and Edelbacher v. 20 Calderon, 160 F.3d 582 (9th Cir. 1998). In Phillips, it had been fifteen years since Phillips “was 21 convicted of murder and first sentenced to death, and ten years since the state supreme court 22 affirmed his conviction and vacated his sentence.” 56 F.3d at 1032. Phillips was resentenced to 23 death and there was “no end in sight” or “indication that Phillips’ appeal from his [re]sentence 24 [would] be decided anytime in the near future.” Id. at 1038, 1032. The Ninth Circuit held that 25 “[i]n light of the extraordinary delay . . . Phillips may bring his habeas petition regarding the 26 constitutionality of his conviction despite the fact that the state has not yet made a final ruling on 27 his sentence.” Id. at 1033. In Edelbacher, the Ninth Circuit held that “[w]hen there is a pending state penalty retrial and no unusual circumstances, we decline to depart from the general rule that 1 a petitioner must await the outcome of the state proceedings before commencing his federal 2 habeas corpus action.” 160 F.3d at 582–83. In so holding, the Ninth Circuit emphasized the 3 “narrow holding in Phillips,” and found Phillips distinguishable “in several material respects”: 4 (1) a retrial of the penalty phase in state court is ongoing; (2) there is no assignment of the necessary capital or non-capital status in 5 this case; (3) there are no “unusual circumstances” which might suggest that “no end is in sight” to the state court proceedings and 6 (4) the delay in question is not attributable to an “ineffective” state process, but primarily to the extended proceedings relating to the 7 guilt issue. 8 Edelbacher, 160 F.3d at 584. 9 Here, the Court finds that the instant matter is more akin to Edelbacher than Phillips.

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Carlos Alfonso Bolanos v. Luis Garnica, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carlos-alfonso-bolanos-v-luis-garnica-caed-2026.