(HC) Flores v. The People

CourtDistrict Court, E.D. California
DecidedApril 17, 2024
Docket1:24-cv-00444
StatusUnknown

This text of (HC) Flores v. The People ((HC) Flores v. The People) 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) Flores v. The People, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF CALIFORNIA 8 9 10 11 JOAQUIN FLORES, ) Case No.: 1:24-cv-00444-SKO (HC) ) 12 Petitioner, ) ORDER DISMISSING PETITION WITH LEAVE ) TO FILE A FIRST AMENDED PETITION 13 v. ) ) [THIRTY DAY DEADLINE] 14 ) 15 THE PEOPLE, ) ) 16 Respondent. ) ) 17 18 Petitioner is a state prisoner proceeding pro se and in forma pauperis with a petition for writ of 19 habeas corpus pursuant to 28 U.S.C. § 2254. A preliminary screening of the petition reveals that the 20 petition fails to name a proper respondent, fails to demonstrate exhaustion of state remedies, and fails 21 to present cognizable grounds for relief. Therefore, the Court will DISMISS the petition with leave to 22 file an amended petition. 23 I. DISCUSSION 24 A. Preliminary Review of Petition 25 Rule 4 of the Rules Governing Section 2254 Cases requires the Court to make a preliminary 26 review of each petition for writ of habeas corpus. The Court must summarily dismiss a petition “[i]f it 27 plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief in 28 the district court . . . .” Rule 4; O’Bremski v. Maass, 915 F.2d 418, 420 (9th Cir. 1990). The Advisory 1 Committee Notes to Rule 8 indicate that the Court may dismiss a petition for writ of habeas corpus, 2 either on its own motion under Rule 4, pursuant to the respondent’s motion to dismiss, or after an 3 answer to the petition has been filed. 4 B. Failure to Name a Proper Respondent 5 Petitioner names “The People” as Respondent. A petitioner seeking habeas corpus relief under 6 28 U.S.C. § 2254 must name the state officer having custody of him as the respondent to the petition. 7 Rule 2 (a) of the Rules Governing § 2254 Cases; Ortiz-Sandoval v. Gomez, 81 F.3d 891, 894 (9th Cir. 8 1996); Stanley v. California Supreme Court, 21 F.3d 359, 360 (9th Cir. 1994). Normally, the person 9 having custody of an incarcerated petitioner is the warden of the prison in which the petitioner is 10 incarcerated because the warden has "day-to-day control over" the petitioner. Brittingham v. United 11 States, 982 F.2d 378, 379 (9th Cir. 1992); see also Stanley, 21 F.3d at 360. However, the chief officer 12 in charge of state penal institutions is also appropriate. Ortiz, 81 F.3d at 894; Stanley, 21 F.3d at 360. 13 Petitioner’s failure to name a proper respondent requires dismissal of his habeas petition for 14 lack of jurisdiction. Stanley, 21 F.3d at 360; Olson v. California Adult Auth., 423 F.2d 1326, 1326 15 (9th Cir. 1970); see also Billiteri v. United States Bd. Of Parole, 541 F.2d 938, 948 (2nd Cir. 1976). 16 However, the Court will give Petitioner the opportunity to cure this defect by amending the petition to 17 name a proper respondent, such as the warden of his facility. See West v. Louisiana, 478 F.2d 1026, 18 1029 (5th Cir. 1973), vacated in part on other grounds, 510 F.2d 363 (5th Cir. 1975) (en banc) 19 (allowing petitioner to amend petition to name proper respondent); Ashley v. State of Washington, 394 20 F.2d 125 (9th Cir. 1968) (same). 21 C. Failure to Demonstrate Exhaustion of State Remedies 22 A petitioner who is in state custody and wishes to collaterally challenge his conviction by a 23 petition for writ of habeas corpus must exhaust state judicial remedies. 28 U.S.C. § 2254(b)(1). The 24 exhaustion doctrine is based on comity to the state court and gives the state court the initial 25 opportunity to correct the state's alleged constitutional deprivations. Coleman v. Thompson, 501 U.S. 26 722, 731 (1991); Rose v. Lundy, 455 U.S. 509, 518 (1982). 27 A petitioner can satisfy the exhaustion requirement by providing the highest state court with a 28 full and fair opportunity to consider each claim before presenting it to the federal court. Duncan v. 1 Henry, 513 U.S. 364, 365 (1995). A federal court will find that the highest state court was given a full 2 and fair opportunity to hear a claim if the petitioner has presented the highest state court with the 3 claim’s factual and legal basis. Duncan, 513 U.S. at 365 (legal basis); Kenney v. Tamayo-Reyes, 504 4 U.S. 1, 112 S.Ct. 1715, 1719 (1992) (factual basis). 5 Petitioner states he appealed to the California Court of Appeals, Fifth Appellate District, and 6 the appeal was affirmed in part and reversed in part on February 1, 2023. (Doc. 1 at 2.) In the space 7 provided to indicate whether Petitioner sought further review of the decision on appeal by a higher 8 state court, the answer is left blank. (Doc. 1 at 2.) Thus, it appears Petitioner has not raised his claims 9 to the California Supreme Court, and the claims are unexhausted. It is possible that Petitioner did 10 exhaust his state remedies but simply neglected to provide the information. Petitioner will be provided 11 an opportunity to include the information in his amended petition. 12 D. Failure to State a Cognizable Federal Claim 13 The basic scope of habeas corpus is prescribed by statute. Title 28 U.S.C. § 2254(a) states: 14 The Supreme Court, a Justice thereof, a circuit judge, or a district court shall entertain an application for a writ of habeas corpus in behalf of a person in custody pursuant to a 15 judgment of a State court only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States. 16 17 (emphasis added). See also Rule 1 to the Rules Governing Section 2254 Cases in the United States 18 District Court. The Supreme Court has held that “the essence of habeas corpus is an attack by a 19 person in custody upon the legality of that custody . . .” Preiser v. Rodriguez, 411 U.S. 475, 484 20 (1973). 21 To succeed in a petition pursuant to 28 U.S.C. § 2254, Petitioner must demonstrate that the 22 adjudication of his claim in state court 23 (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United 24 States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding. 25 26 28 U.S.C. § 2254(d)(1), (2).

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Related

Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Keeney v. Tamayo-Reyes
504 U.S. 1 (Supreme Court, 1992)
Daniel Olson v. California Adult Authority
423 F.2d 1326 (Ninth Circuit, 1970)
Limmie West, III v. State of Louisiana
478 F.2d 1026 (Fifth Circuit, 1973)
Limmie West, III v. State of Louisiana
510 F.2d 363 (Fifth Circuit, 1975)
Mark Brittingham v. United States
982 F.2d 378 (Ninth Circuit, 1992)
Jerry F. Stanley v. California Supreme Court
21 F.3d 359 (Ninth Circuit, 1994)
Duncan v. Henry
513 U.S. 364 (Supreme Court, 1995)
Union Bank & Trust Co. of Helena v. Loble
20 F.2d 124 (Ninth Circuit, 1927)
Ortiz-Sandoval v. Gomez
81 F.3d 891 (Ninth Circuit, 1996)

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Bluebook (online)
(HC) Flores v. The People, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hc-flores-v-the-people-caed-2024.