Eric Curtis Lund v. Izen Locatelli, et al.

CourtDistrict Court, E.D. California
DecidedSeptember 25, 2025
Docket2:21-cv-01831
StatusUnknown

This text of Eric Curtis Lund v. Izen Locatelli, et al. (Eric Curtis Lund v. Izen Locatelli, et al.) 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
Eric Curtis Lund v. Izen Locatelli, et al., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 ERIC CURTIS LUND, No. 2:21-cv-01831-DJC-SCR 12 Petitioner, 13 v. ORDER 14 IZEN LOCATELLI, et al., 15 Respondents. 16 17 Petitioner, proceeding through counsel, filed this application for a writ of 18 habeas corpus pursuant to 28 U.S.C. § 2254. The matter was referred to a United 19 States Magistrate Judge pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 302. 20 Presently pending is Respondents’ partial Motion to Dismiss the Third 21 Amended Petition. (ECF No. 39.) On March 20, 2025, the Magistrate Judge filed 22 Findings and Recommendations herein which were served on all parties and which 23 contained notice to all parties that any objections to the Findings and 24 Recommendations were to be filed within twenty-one days. Petitioner filed 25 Objections to the Findings and Recommendations as well as a Request for Judicial 26 Notice. (ECF Nos. 47–48.) Respondents submitted a Response to Petitioner’s 27 Objections and an Opposition to the Request for Judicial Notice. (ECF Nos. 50, 52.) 28 Petitioner filed a Reply to Respondent’s Opposition to the Request for Judicial Notice. 1 (ECF No. 51.) Petitioner separately filed Objections to the Magistrate Judge’s Order 2 denying one of Petitioner’s prior requests for judicial notice to which Respondents 3 have also responded. (ECF Nos. 46, 49.) 4 I. New Request for Judicial Notice 5 Petitioner requests that the Court take judicial notice of excerpts of the 6 transcripts of his testimony in a civil rights trial, which describes prison official’s 7 confiscation of his legal mail. (ECF No. 48.) Petitioner relies on this new evidence in 8 support of his argument that the procedural default of any claims in his Third 9 Amended Petition should be excused. The Court denies Petitioner’s request for 10 judicial notice because this new evidence was submitted for the first time in his 11 objections to the Magistrate Judge’s findings and recommendations. Petitioner’s 12 newly proffered basis to excuse his procedural default could have been raised earlier 13 by submitting his own sworn declaration, especially since he has known of these facts 14 since 2020 and because he is represented by counsel in these proceedings. As such, 15 this court exercises its discretion and declines to consider it. See United States v. 16 Howell, 231 F.3d 615, 621 (9th Cir. 2000) (stating that a district court is not required to 17 consider new evidence presented in objections to a magistrate judge’s 18 recommendation). 19 II. Findings and Recommendations on Respondents’ Motion to Dismiss 20 In accordance with the provisions of 28 U.S.C. § 636(b)(1)(C) and Local Rule 21 304, this court has conducted a de novo review of this case and the Magistrate 22 Judge’s Findings and Recommendations on Respondents’ Motion to Dismiss. Having 23 carefully reviewed the entire file, the Court finds the Findings and Recommendations 24 to be supported by the record and by proper analysis. 25 Throughout his Objections, Petitioner repeatedly raises that “the Magistrate 26 Judge failed to address Lund’s legal arguments” and lists “arguments” that the 27 Findings and Recommendations allegedly did not address. (See ECF No. 47 at 1, 3– 28 6.) That the Magistrate Judge did not expressly list and reject every single argument 1 and sub-argument raised by Petitioner does not render the Findings and 2 Recommendations improper or inadequate. The Magistrate Judge was under no 3 obligation to address in writing every argument made by Petitioner in his Opposition. 4 See United States v. Howe, No. 2:19-cv-00421-DCN, 2021 WL 276696, at *3 (D. Idaho 5 Jan. 26, 2021). As is readily apparent from the Findings and Recommendations, the 6 Magistrate Judge reviewed and considered all of the arguments raised by Petitioner. 7 Whether explicitly or implicitly, the Findings and Recommendations are clear as to the 8 Magistrate Judge’s ruling on each of Plaintiff’s arguments and the basis for the 9 Magistrate Judge’s ultimate recommendations. 10 The Court is also unpersuaded by Petitioner’s claims that the Magistrate Judge 11 misapplied the law. The Magistrate Judge’s determination that the “Villa Bar” was a 12 state procedural bar that was independent of federal law and adequate to bar habeas 13 review on the merits was soundly reasoned. The Villa Bar is both independent and 14 adequate. See Lee v. Harris, 226 F. Supp. 3d 992, 996–98 (N.D. Cal. 2016). Contrary 15 to Petitioner’s assertion to the contrary, the Magistrate Judge was not required to 16 presume the state court’s denial was based in part upon federal grounds, as the state 17 court made clear that it was resting its decision on independent and adequate state 18 grounds. See Bennet v. Mueller, 322 F.3d 573, 581 (9th Cir. 2003). 19 The Findings and Recommendations are also correct in their application of the 20 Statute of Limitations Bar. Contrary to Petitioner’s arguments, the Magistrate Judge 21 did not err in finding that the prosecutorial misconduct claims for introducing 22 evidence of the wrong network, questioning to solely make inferences, asking 23 petitioner if he had a motive to lie, and invading spousal privilege, did not relate back 24 to prior, timely petitions. Each of these claims in the Third Amended Petition involves 25 different underlying facts from claims asserted in prior petitions. 26 The Magistrate Judge’s determination as to cause and prejudice analysis for 27 application is also accurate; Petitioner failed to establish cause for his defaults. In his 28 Objections, Petitioner seeks to present new arguments for cause and prejudice to 1 overcome the imposed procedural bars. (ECF No. 47 at 13–25.) Petitioner had ample 2 opportunity to address these arguments before the Magistrate Judge. Petitioner is 3 also represented by counsel and has not presented good cause why these arguments 4 are only now raised in his Objections. On these facts, the Court will exercise its 5 discretion and decline to consider these new arguments. See Brown v. Roe, 279 F.3d 6 742, 744 (9th Cir. 2002). 7 Finally, the Magistrate Judge did not misapply the law in determining that 8 Petitioner had not met his burden to establish actual innocence under Schlup v. Delo, 9 513 U.S. 298 (1995). Petitioner’s argument that denying review would be a 10 miscarriage of justice relied on the alleged cumulative effect of the errors alleged. 11 (ECF No. 37 ¶ 186; ECF No. 40 at 14–15; ECF No. 47 at 6–7.) To fall within the limited 12 exception for a fundamental miscarriage of justice, Petitioner must show that “more 13 likely than not, in light of the new evidence, no reasonable juror would find him guilty 14 beyond a reasonable doubt—or, to remove the double negative, that more likely than 15 not any reasonable juror would have reasonable doubt.” House v. Bell, 547 U.S. 518, 16 538 (2006). The cumulative effect of legal errors suggested by Petitioner does not 17 meet this burden. As noted by the Magistrate Judge, Petitioner has not 18 “supplement[ed] his constitutional claim with a colorable showing of factual 19 innocence,” as is necessary to fall within this limited exception. Casey v. Moore, 386 20 F.3d 896, 921 n. 27 (9th Cir.

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Related

Herrera v. Collins
506 U.S. 390 (Supreme Court, 1993)
Schlup v. Delo
513 U.S. 298 (Supreme Court, 1995)
House v. Bell
547 U.S. 518 (Supreme Court, 2006)
United States v. Sean Howell
231 F.3d 615 (Ninth Circuit, 2000)
Ching Lee v. Harris
226 F. Supp. 3d 992 (N.D. California, 2016)

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Bluebook (online)
Eric Curtis Lund v. Izen Locatelli, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-curtis-lund-v-izen-locatelli-et-al-caed-2025.