(HC) Briscoe, III v. Eldridge

District Court, E.D. California·Decided March 16, 2021·No. 1:19-cv-00389·Unknown

Opinion

JAMES ROBERT BRISCOE, III, No. 1:19-cv-00389-DAD-JLT (HC) Petitioner, v. ORDER ADOPTING FINDINGS AND RECOMMENDATIONS IN PART

Respondent. (Doc. Nos. 17, 52)

Petitioner James Robert Briscoe, III, is a state prisoner proceeding pro se and in forma pauperis with a petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254. The matter was referred to a United States Magistrate Judge pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 302. On February 3, 2020, the assigned magistrate judge issued findings and recommendations, recommending that the petition of writ of habeas corpus be denied. (Doc. No. 52.) These findings and recommendations were served upon petitioner and contained notice that any objections thereto were to be filed within thirty (30) days from the date of service of that order. (Id. at 9.) After the granting of multiple extensions of time to do so, on June 29, 2020, petitioner’s objections to the findings and recommendation were timely filed. (Doc. No. 60.) ///// In accordance with the provisions of 28 U.S.C. § 636(b)(1)(C), this court has conducted a de novo review. Having carefully reviewed the entire file, including petitioner’s objections, the court concludes that the findings and recommendation are supported by the record and proper analysis; however, the undersigned notes that the pending findings and recommendations addressed only claim 1 of the petition, but did not address petitioner’s claim 3 in which he asserted that he had received ineffective assistance of counsel.1 Thus, the undersigned will adopt the findings and recommendations along with the analysis of claim 3 set forth below. The pending findings and recommendations determined that petitioner’s claim 1, in which he asserted that his guilty plea was improperly induced by the promise of time credits that he did not receive, had not been exhausted in state court and thus was subject to dismissal on that basis. (Doc. No. 52 at 8.) The pending findings and recommendations went on to correctly outline that even if the court were able to address this claim on the merits, dismissal would still be recommended because “federal habeas relief is not available to state prisoners challenging state law.” (Id.) (citing Estelle v. McGuire, 502 U.S. 62, 67 (1991) (“We have stated many times that federal habeas corpus relief does not lie for errors of state law.”); Langford v. Day, 110 F.3d 1380, 1389 (9th Cir. 1997) (“alleged errors in the application of state law are not cognizable in federal habeas corpus” proceedings)). In his objections, petitioner does not address his failure to exhaust claim 1 by first presenting it to the California Supreme Court. Petitioner instead raises similar arguments to those already addressed and properly rejected in the pending findings and recommendations. (Cf. Doc. 1 In his objections, petitioner noted that his ineffective assistance of counsel claim (Doc. No. 17 at 11–12) was not addressed by the pending findings and recommendations. (Doc. No. 60 at 9– 10.) Petitioner’s First Amended Petition, filed April 18, 2019, asserted three claims for federal habeas relief, challenging his sentence on the basis that: (1) his presentence custody credits were miscalculated, which petitioner contends was in violation of his plea agreement; (2) he was assessed fines and restitution that were not a part of his original plea agreement; and (3) he received ineffective assistance of counsel related to those alleged issues in connection with his entry of his guilty plea. (Doc. No. 17 at 1–19.) After a motion to dismiss claim 2 was filed (Doc. No. 28), plaintiff voluntarily moved to dismiss that claim (Doc. No. 31), which the assigned magistrate judge granted on July 29, 2019. (Doc. No. 36.) Thus, at the time the February 3, 2020 findings and recommendations were issued, both claim 1 and 3 remained pending before this court. No. 60 at 2–4, 10–11 with Doc. No. 52 at 5–9.) In short, petitioner’s objections provide no basis upon which to reject the recommendation that claim 1 of the pending petition be dismissed. The court turns now to claim 3 of the pending petition. Therein, petitioner asserts that he received ineffective assistance of counsel in connection with his plea because his attorney failed to object to the change in the presentence time credits he received, which was different than the credits petitioner claims he was promised at the time he entered his plea. (Doc. No. 17 at 11–12.) Petitioner’s ineffective assistance claim (claim 3) appears to have been exhausted before the California Supreme Court. (Doc. No. 34-7 at 6.) The Sixth Amendment guarantees a criminal defendant the effective assistance of counsel. Strickland v. Washington, 466 U.S. 668 (1984). To support a claim of ineffective assistance of counsel, a petitioner must first show that, considering all the circumstances, counsel’s performance fell below an objective standard of reasonableness. 466 U.S. at 687–88. “In determining deficiency, a ‘a court must indulge a strong presumption that counsel’s conduct fell within the wide range of reasonable professional assistance[.]’” Wood v. Ryan, 693 F.3d 1104, 1118 (9th Cir. 2012) (quoting Strickland, 466 U.S. at 689). After a petitioner identifies such acts or omissions that are alleged not the result of reasonable professional judgment, the court must determine whether, in light of all the circumstances, the identified acts or omissions were outside the wide range of professionally competent assistance. Id. at 690; Wiggins v. Smith, 539 U.S. 510, 521, (2003). Second, a petitioner must establish that he was prejudiced by counsel’s deficient performance. Strickland, 466 U.S. at 693–94. Prejudice is found where “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 694. A reasonable probability is “a probability sufficient to undermine confidence in the outcome.” Id.; see also Williams, 529 U.S. at 391–92; Laboa v. Calderon, 224 F.3d 972, 981 (9th Cir. 2000). The focus of the prejudice analysis is on “whether counsel’s deficient performance renders the result of the trial unreliable or the proceeding fundamentally unfair.” Lockhart v. Fretwell, 506 U.S. 364, 372 (1993). After the passage of Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), a reviewing court is not permitted to grant habeas relief in response to a claim of ineffective assistance of counsel unless the state court’s decision unreasonably applied the Strickland standard. Knowles v. Mirzayance, 556 U.S. 111, 122 (2009). In advancing his ineffective of counsel claim, petitioner asserts that he received less time credit than he was entitled to and that his attorney failed to object to the time credits he was awarded and failed to object to a hearing held outside petitioner’s presence where the time credits were discussed. Petitioner claims that his attorney proceeded in his absence at that hearing because he knew petitioner would have objected to the award of less time credit than was discussed at the time petitioner entered his plea. (Doc. No. 17 at 11–12.) However, as addressed in the pending findings and

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Related

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466 U.S. 668 (Supreme Court, 1984)
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Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Knowles v. Mirzayance
556 U.S. 111 (Supreme Court, 2009)
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Joseph Wood, III v. Charles Ryan
693 F.3d 1104 (Ninth Circuit, 2012)