Hartman v. Knudsen

CourtDistrict Court, D. Montana
DecidedJanuary 14, 2022
Docket9:21-cv-00146
StatusUnknown

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

Bluebook
Hartman v. Knudsen, (D. Mont. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA MISSOULA DIVISION

KIP HARTMAN, Cause No. CV 21-146-M-DWM

Petitioner,

vs. ORDER DISMISSING PETITION AND DENYING CERTIFICATE OF AUSTIN KNUDSEN, et al., APPEALABILITY

Respondents.

This case comes before the Court on Petitioner Hartman’s application for writ of habeas corpus under 28 U.S.C. § 2241. Hartman faces a second trial in Montana’s Nineteenth Judicial District Court, Lincoln County, and asserts it is precluded by the Double Jeopardy Clause. Respondents (“the State”) filed an answer on December 21, 2021. Hartman replied on January 11, 2022. I. Jurisdiction The Court has jurisdiction pursuant to 28 U.S.C. § 2241 because Hartman contends he is “in custody in violation of the Constitution . . . of the United States.” 28 U.S.C. § 2241(c)(3). His conditional release and obligation to appear for trial constitute “custody,” see, e.g., Hensley v. Municipal Court, 411 U.S. 345, 351–53 (1973), and he contends that continuing this custody violates the Fifth Amendment’s guarantee against double jeopardy, see Benton v. Maryland, 395 U.S. 784, 793–96 (1969).

The more common jurisdictional statute, 28 U.S.C. § 2254, does not apply. Hartman is not “in custody pursuant to a judgment.” 28 U.S.C. § 2254(a). Unlike other constitutional claims, a double jeopardy claim may be heard in federal court

before entry of judgment because “the Double Jeopardy Clause protects an individual against more than being subjected to double punishments. It is a guarantee against being twice put to trial for the same offense.” Abney v. United States, 431 U.S. 651, 660–61 (1977); see also, e.g., Dominguez v. Kernan, 906

F.3d 1127, 1132 n.7 (9th Cir. 2018); Brown v. Ahern, 676 F.3d 899, 901 (9th Cir. 2012); Stow v. Murashige, 389 F.3d 880, 885–88 (9th Cir. 2004). II. Exhaustion

28 U.S.C. § 2254(b) and (c) require state prisoners to exhaust their claims in state court before filing in federal court. As § 2254 does not apply, neither does its exhaustion requirement. But the statute codifies longstanding case law requiring persons in state custody to present their federal constitutional claims in state court

before proceeding in federal court. Regardless of the lack of statutory command, the exhaustion requirement is essential to preserve comity between state and federal courts. See, e.g., Rose v. Lundy, 455 U.S. 509, 520 (1982); Ex parte

Royall, 117 U.S. 241, 251 (1886). It applies here. The State asserts that Hartman has not properly exhausted his claim in state court. See Answer (Doc. 5) at 41–50. Hartman presented his double jeopardy

claim to the Montana Supreme Court on October 29, 2021, in a petition for writ of supervisory control. See Hartman v. Nineteenth Jud. Dist. Court, No. OP 21-0536 (Mont. filed Oct. 29, 2021). The October petition happened to be Hartman’s fourth

application for supervisory control. The first three were filed before Hartman’s first trial. His fourth petition was the first one he filed after the trial court declared a mistrial and set a new trial. Thus, the fourth petition was Hartman’s first and only one raising a claim of double jeopardy.

The Montana Supreme Court holds that “constitutional double jeopardy rulings by a district court may be challenged prior to a final judgment only by way of a petition for writ of supervisory control, as authorized by” Montana Rule of

Appellate Procedure 14(3). State v. Burton, 407 P.3d 280, 286 ¶ 18 (Mont. 2017). Supervisory control, however, remains “an extraordinary remedy,” available only on “a case-by-case basis.” Mont. R. App. P. 14(3). The criteria governing such petitions are set forth in Montana Rule of

Appellate Procedure 14(3). A petitioner must meet three elements, the third of which may be met by one or more of three alternatives: Supervisory control . . . is sometimes justified when urgency or emergency factors exist making the normal appeal process inadequate, when the case involves purely legal questions, and when one or more of the following circumstances exist: (a) The other court is proceeding under a mistake of law and is causing a gross injustice;

(b) Constitutional issues of state-wide importance are involved;

(c) The other court has granted or denied a motion for substitution of a judge in a criminal case.

Mont. R. App. P. 14(3) (eff. Oct. 1, 2011). In his fourth petition, Hartman asserted that the following criteria governed: Original jurisdiction is appropriate under Mont. R. App. P. 14(2) and 14(3) because a writ of supervisory control is appropriate where the case involves (1) constitutional issues of major statewide importance; (2) purely legal questions of statutory/constitutional construction; or (3) urgency and emergency factors make the normal appeal process inadequate.

Pet. for Writ of Supervisory Control (Doc. 1-2) at 14, Hartman, No. OP 21-0536. Hartman’s petition stated three elements, but it presented them as if meeting one of them would suffice. Apart from misstating the elements, the petition did not further address them. It proceeded directly, and exclusively, to an argument showing why Hartman believed the trial court erred in declaring a mistrial. See id. at 14–21. The Montana Supreme Court held: Because he has failed to meet the threshold procedural requirements for this Court to consider whether the matter he seeks to raise is appropriate for writ of supervisory control, we have not considered the merits of Hartman’s substantive arguments.

Order at 3, Hartman, No. OP 21-0536 (Mont. Nov. 9, 2021); see also Mont. R. App. P 14(5)(B)(i), (iii). “[O]nce the state courts have ruled upon a claim,” the exhaustion

requirement is met. See Castille v. Peoples, 489 U.S. 346, 350 (1989) (discussing Brown v. Allen, 344 U.S. 443, 447 (1953)). The requirement is also met if the petitioner presents the claim in an appeal as of right, see, e.g., Mont. Code Ann. §§

46-20-101, -104, 46-21-203, but the claim is “ignored (and therefore impliedly rejected)” by the state court. See Peoples, 489 U.S. at 351 (citing Smith v. Digmon, 434 U.S. 332, 333 (1978) (per curiam)). But “where the claim has been presented for the first and only time in a

procedural context in which its merits will not be considered” unless the petitioner meets exceptional criteria, see Peoples, 489 U.S. at 351 (describing Pennsylvania law requiring “special and important reasons” to hear petition for writ of allocatur),

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Related

Ex Parte Royall
117 U.S. 241 (Supreme Court, 1886)
Ex Parte Hawk
321 U.S. 114 (Supreme Court, 1944)
Brown v. Allen
344 U.S. 443 (Supreme Court, 1953)
Benton v. Maryland
395 U.S. 784 (Supreme Court, 1969)
Pitchess v. Davis
421 U.S. 482 (Supreme Court, 1975)
Abney v. United States
431 U.S. 651 (Supreme Court, 1977)
Smith v. Digmon
434 U.S. 332 (Supreme Court, 1978)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Castille v. Peoples
489 U.S. 346 (Supreme Court, 1989)
Gray v. Netherland
518 U.S. 152 (Supreme Court, 1996)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Brown v. Ahern
676 F.3d 899 (Ninth Circuit, 2012)
Steven Donald Stow v. Albert Murashige
389 F.3d 880 (Ninth Circuit, 2004)
State v. D. Burton
2017 MT 306 (Montana Supreme Court, 2017)
Florencio Dominguez v. Scott Kernan
906 F.3d 1127 (Ninth Circuit, 2018)
Gonzalez v. Thaler
181 L. Ed. 2d 619 (Supreme Court, 2012)

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Hartman v. Knudsen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hartman-v-knudsen-mtd-2022.