(HC) Carman v. Ratliff

CourtDistrict Court, E.D. California
DecidedAugust 15, 2025
Docket2:24-cv-03755
StatusUnknown

This text of (HC) Carman v. Ratliff ((HC) Carman v. Ratliff) 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) Carman v. Ratliff, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 FOR THE EASTERN DISTRICT OF CALIFORNIA 9 10 WILLIAM DALE CARMAN, No. 24-cv-3755 DAD AC P 11 Petitioner, 12 v. ORDER AND FINDINGS AND RECOMMENDATIONS 13 CALIFORNIA STATE PRISON, 14 Respondent. 15 16 Petitioner, a county prisoner proceeding without counsel, has filed an application for a 17 writ of habeas corpus pursuant to 28 U.S.C. § 2254. 18 I. Background 19 A. State Trial Proceedings 20 Petitioner was convicted on multiple charges by a jury in Nevada County Superior Court 21 Case No. F15-000007. ECF No. 1 at 1. He was sentenced to a prison term of twenty-five years 22 to life plus eleven year four months. ECF No. 9-1 at 7. 23 B. State Post-Conviction Proceedings 24 Petitioner appealed his conviction and sentence to the California Third District Court of 25 Appeal, alleging errors at trial and sentencing in violation of his constitutional rights. ECF No. 2 26 at 2; ECF No. 9-1. The Court of Appeal affirmed the conviction but vacated the sentence and 27 remanded the case for resentencing consistent with retroactive changes to state sentencing law. 28 ECF No. 9-1 at 28-30. Petitioner filed a petition for review in the California Supreme Court 1 (ECF No. 9-2), which was denied on December 27, 2023 (ECF No. 9-3). He did not petition for a 2 writ of certiorari in the United States Supreme Court. ECF No. 1 at 3. At the time the motion to 3 dismiss was filed, petitioner had a resentencing hearing scheduled for February 7, 2025, in the 4 Nevada County Superior Court. ECF No. 9-4; ECF No. 10. Review of the superior court’s 5 docket shows that petitioner’s resentencing has been continued multiple times since that date and 6 the next hearing is currently scheduled for August 18, 2025. 7 C. Federal Proceedings 8 Petitioner filed the instant petition on December 24, 2024, raising multiple grounds for 9 relief.1 ECF No. 1. Respondent filed a motion to dismiss the petition (ECF No. 10), which 10 petitioner opposes (ECF No. 13). 11 II. Motion to Dismiss 12 Respondent2 seeks dismissal pursuant to Younger v. Harris, 401 U.S. 37 (1971), on 13 grounds that petitioner’s conviction was not final when the federal petition was filed and he is 14 still pending resentencing. ECF No. 10. She also asserts that at least one of petitioner’s claims 15 will potentially be mooted by the state court proceedings. Id. at 1-2. She asserts that dismissal is 16 required even if the state court proceedings conclude. Id. at 3. 17 In response, petitioner argues that his upcoming resentencing hearing is only to determine 18 his sentence, not his guilt, and his petition challenges whether he “had a fair trial and all laws 19 were followed.” ECF No. 13. He requests that if his petition is dismissed, he be given 20 permission to file another petition at a later date. Id. 21 III. Abstention Doctrine 22 Under Younger v. Harris, federal courts may not interfere with a pending state criminal 23 prosecution or related proceeding absent “extraordinary circumstances, where the danger of 24 1 Since petitioner is a prisoner proceeding pro se, he is afforded the benefit of the prison mailbox 25 rule. Houston v. Lack, 487 U.S. 266, 276 (1988) (establishing rule that a prisoner’s court 26 document is deemed filed on the date the prisoner delivered the document to prison officials for mailing). 27 2 Respondent requests that Kathleen N. Ratliff, the warden of California Health Care Facility, be substituted as respondent in this case. ECF No. 10 at 1 n.1. The request will be granted, and the 28 Clerk of the Court will be directed to update the docket accordingly. 1 irreparable loss is both great and immediate.” 401 U.S. at 45. “Younger abstention is a 2 jurisprudential doctrine rooted in overlapping principles of equity, comity, and federalism.” 3 Arevalo v. Hennessy, 882 F.3d 763, 765 (9th Cir. 2018) (quoting San Jose Silicon Valley 4 Chamber of Com. Pol. Action Comm. v. City of San Jose, 546 F.3d 1087, 1091-92 (9th Cir. 5 2008)). 6 Abstention is appropriate if four requirements are met: “(1) there is ‘an ongoing state 7 judicial proceeding’; (2) the proceeding ‘implicate[s] important state interests’; (3) there is ‘an 8 adequate opportunity in the state proceedings to raise constitutional challenges’; and (4) the 9 requested relief ‘seek[s] to enjoin’ or has ‘the practical effect of enjoining’ the ongoing state 10 judicial proceeding.” Id. (alteration in original) (quoting ReadyLink Healthcare, Inc. v. State 11 Comp. Ins. Fund, 754 F.3d 754, 758 (9th Cir. 2014)). All four elements must be satisfied to 12 warrant abstention. See AmerisourceBergen Corp. v. Roden, 495 F.3d 1143, 1149 (9th Cir. 13 2007). 14 IV. Discussion 15 All four Younger abstention criteria are met in this case. First, petitioner’s resentencing 16 was admittedly pending in state court when the federal petition was filed, see ECF No. 1 at 7-8, 17 10-12; ECF No. 13, and appears to still be pending. Moreover, even if petitioner’s resentencing 18 and any subsequent appeal had concluded, it is the status of the state court proceeding at the time 19 the federal petition was filed that matters for Younger purposes. Beltran v. State of California, 20 871 F.2d 777, 782 (9th Cir. 1988) (dismissal required under Younger if state court proceedings 21 were ongoing at time action was filed even if they conclude before the court addresses the issue). 22 Therefore, even if petitioner’s state court proceedings conclude prior to the district judge’s 23 consideration of these findings and recommendations, the first Younger requirement is satisfied. 24 See id.; Kitchens v. Bowen, 825 F.2d 1337, 1341 (9th Cir. 1987) (“[T]he critical question is not 25 whether the state proceedings are still ‘ongoing’, but whether ‘the state proceedings were 26 underway before initiation of the federal proceedings.’” (quoting Fresh Int’l Corp. v. Agric. Lab. 27 Rels. Bd., 805 F.2d 1353, 1358 (9th Cir. 1986)). 28 //// 1 Second, criminal proceedings indisputably implicate important state interests for Younger 2 purposes. “[T]he States’ interest in administering their criminal justice systems free from federal 3 interference is one of the most powerful of the considerations that should influence a court 4 considering equitable types of relief.” Kelly v. Robinson, 479 U.S. 36, 49 (1986) (citing 5 Younger, 401 U.S. at 44-45). 6 Third, California’s appellate and post-conviction review process provides an opportunity 7 for consideration of federal constitutional questions. It does not matter to the Younger analysis 8 whether the specific federal claims petitioner wishes to present in this court are part of the 9 pending state proceeding. See Commc’ns Telesystems Int’l v. Cal. Pub. Util. Comm’n, 196 F.3d 10 1011, 1020 (9th Cir. 1999) (“The ‘adequate opportunity’ prong of Younger . . . requires only the 11 absence of ‘procedural bars’ to raising a federal claim in the state proceedings.” (citations 12 omitted)).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
(HC) Carman v. Ratliff, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hc-carman-v-ratliff-caed-2025.