(HC) Araujo v. Johnson

CourtDistrict Court, E.D. California
DecidedFebruary 11, 2025
Docket2:24-cv-01735
StatusUnknown

This text of (HC) Araujo v. Johnson ((HC) Araujo v. Johnson) 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
(HC) Araujo v. Johnson, (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 DAVID ANGEL ARAUJO, No. 2:24-cv-01735-EFB (PC) 12 Petitioner, 13 v. ORDER 14 JASON JOHNSON, 15 Respondent. 16 17 Petitioner is a state prisoner proceeding with counsel in this petition for a writ of habeas 18 corpus brought under 28 U.S.C. § 2254. ECF No. 1. He has filed a motion to stay the petition 19 pending exhaustion of state court remedies. ECF No. 2. 20 I. Background 21 Petitioner was convicted of several state crimes related to domestic violence on September 22 24, 2021. ECF No. 1. He was sentenced on April 14, 2022 to four years in prison. Id. In the 23 instant petition, petitioner raises three claims: (1) that he was deprived of due process by the 24 giving of a certain jury instruction, (2) that his trial counsel rendered ineffective assistance, and 25 (3) that the police and prosecutor committed misconduct. Id. His direct appeal was denied, and 26 the California Supreme Court denied his petition for direct review on October 11, 2023. Id. at 3- 27 4. Petitioner asks the court to stay the petition under either Kelly v. Small, 315 F.3d 1063, (9th 28 Cir. 2003) or Rhines v. Weber, 544 U.S. 269 (2005) while he exhausts the second and third claims 1 (hereinafter “Claims 2 and 3”) in state court. 2 II. Screening Order 3 A judge “entertaining an application for a writ of habeas corpus shall forthwith award the 4 writ or issue an order directing the respondent to show cause why the writ should not be granted, 5 unless it appears from the application that the applicant or person detained is not entitled thereto.” 6 28 U.S.C. § 2243. It is not apparent from the face of the application that the petitioner is not 7 entitled to relief. Accordingly, the court will direct service of the petition on respondent. 8 Because the court will grant the request for a stay, see below, respondent need not respond to the 9 petition until petitioner has exhausted Claims 2 and 3 and filed a second amended petition. 10 III. Analysis 11 A district court may not grant a petition for a writ of habeas corpus unless the petitioner 12 has exhausted available state court remedies. 28 U.S.C. § 2254(b)(1). Where a federal habeas 13 petitioner has failed to exhaust a claim in the state courts, she may ask the federal court to stay its 14 consideration of her petition while she returns to state court to complete exhaustion. Two 15 procedures may be used in staying a petition — one provided for by Kelly v. Small, 315 F.3d 16 1063 (9th Cir. 2002) and the other by Rhines v. Weber, 544 U.S. 269 (2005). King v. Ryan, 564 17 F.3d 1133, 1138-41 (9th Cir. 2009). Under the Kelly procedure, the district court may stay a 18 petition containing only exhausted claims and hold it in abeyance pending exhaustion of 19 additional claims which may then be added to the petition through amendment. Kelly, 315 F.3d at 20 1070-71; King, 564 F.3d at 1135. If the federal petition contains both exhausted and unexhausted 21 claims (a so-called “mixed” petition), a petitioner seeking a stay under Kelly must first dismiss 22 the unexhausted claims from the petition and seek to add them back in through amendment after 23 exhausting them in state court. King, 564 F.3d at 1138-39. The previously unexhausted claims, 24 once exhausted, must be added back into the federal petition within the statute of limitations 25 provided for by 28 U.S.C. § 2244(d)(1), however. King, 564 F.3d at 1140-41. Under that statute, 26 a one-year limitation period for seeking federal habeas relief begins to run from the latest of the 27 date the judgment became final on direct review, the date on which a state-created impediment to 28 filing is removed, the date the United States Supreme Court makes a new rule retroactively 1 applicable to cases on collateral review or the date on which the factual predicate of a claim could 2 have been discovered through the exercise of due diligence. 28 U.S.C. § 2241(d)(1). A federal 3 habeas petition does not toll the limitations period under 28 U.S.C. § 2244(d)(2). Duncan v. 4 Walker, 533 U.S. 167, 181-82 (2001). 5 Under Rhines, a district court may stay a mixed petition in its entirety, without requiring 6 dismissal of the unexhausted claims, while the petitioner exhausts them in state court. King, 564 7 F.3d at 1139-40. Unlike the Kelly procedure, however, Rhines requires that the petitioner show 8 good cause for failing to exhaust the claims in state court prior to filing the federal petition. 9 Rhines, 544 U.S. at 277-78; King, 564 F.3d at 1139. In addition, a stay pursuant to Rhines is 10 inappropriate where the unexhausted claims are “plainly meritless” or where the petitioner has 11 engaged in “abusive litigation tactics or intentional delay.” Id. 12 Petitioner argues that a stay is appropriate under either the Kelly or Rhines frameworks. 13 He argues that there is good cause to stay the case because petitioner did not retain current 14 counsel until April 2022, who required time to investigate the case and review the trial record. 15 ECF No. 2 at 5-6. Petitioner, who is not trained in law, was unaware of Claims 2 and 3; current 16 counsel discovered those claims while investigating the file. 17 Under Rhines, “good cause” consists of a reasonable excuse supported by sufficient 18 evidence. Blake v. Baker, 745 F.3d 977, 982 (9th Cir. 2014). It does not require a showing of 19 extraordinary circumstances. Jackson v. Roe, 425 F.3d 654, 661-62 (9th Cir. 2005). While the 20 parameters of good cause under Rhines are not well-defined, courts have found good cause 21 where: (1) petitioner was reasonably confused about the timeliness of a state filing (Pace v. 22 DiGuglielmo, 544 U.S. 408, 416 (2005)); (2) petitioner lacked counsel in state post-conviction 23 proceedings (Dixon v. Baker, 847 F.3d 714, 721-22 (9th Cir. 2017)); and (3) petitioner’s state 24 post-conviction counsel rendered ineffective assistance (Blake, 745 F.3d at 982-93). 25 A review of the record and the publicly-available dockets of the California Supreme Court 26 and the California Court of Appeal for the Fifth District (available at 27 appellatecases.courtinfo.ca.gov) reveals that current counsel has represented petitioner during his 28 direct appeals to both courts. The California Supreme Court’s public docket also reveals that 1 petitioner, represented by current counsel, filed a habeas petition in that court on December 6, 2 2024, roughly six months after this action was filed. The motion to stay contains no explanation 3 of why the state petition was not filed earlier. Surely if counsel knew of Claims 2 and 3 when this 4 action was filed in June 2024, counsel could have presented those claims to the state supreme 5 court prior to December.

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Related

Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Leahy v. Raytheon Corporation
315 F.3d 11 (First Circuit, 2002)
Andreas Kelly v. Larry Small, Warden
315 F.3d 1063 (Ninth Circuit, 2003)
Fred Jay Jackson v. Ernest C. Roe, Warden
425 F.3d 654 (Ninth Circuit, 2005)
Mayle v. Felix
545 U.S. 644 (Supreme Court, 2005)
Alfonso Blake v. Renee Baker
745 F.3d 977 (Ninth Circuit, 2014)
Terry Dixon v. Renee Baker
847 F.3d 714 (Ninth Circuit, 2017)
Resolution Trust Corp. v. Eason
17 F.3d 1126 (Eighth Circuit, 1994)

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Bluebook (online)
(HC) Araujo v. Johnson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hc-araujo-v-johnson-caed-2025.