(HC) Iniguez v. Thompson

District Court, E.D. California·Decided September 1, 2020·No. 2:19-cv-01318·Unknown

Opinion

CRUZ INIGUEZ, No. 2:19-cv-1318-EFB P Petitioner, v. ORDER AND FINDINGS AND RECOMMENDATIONS PAUL THOMPSON, Warden, Respondent. Petitioner is a federal prisoner proceeding without counsel in this petition for writ of habeas corpus brought under 28 U.S.C. § 2241. ECF No. 1. Respondent has filed a motion to dismiss the petition. ECF No. 9. For the reasons that follow, the motion must be granted. I. Background Petitioner is confined in federal prison at FCI Herlong. ECF No. 1 at 1. He was convicted in 2000 in the United States District Court for the Central District of California on a variety of drug distribution charges and, following some appellate process not relevant here, received a sentence of 360 months’ imprisonment on four counts, to be served concurrently. Id. at 11. Petitioner claims that his sentence was enhanced under a part of 21 U.S.C. § 841(b)(1)(C) that provides for enhancement where “death or serious bodily injury results from the use of” the distributed drugs. Id. at 18. ///// Petitioner filed a motion to vacate, set aside or correct his sentence pursuant to 28 U.S.C. § 2255 in 2007; it was denied the following year. Id. at 11-12. In 2014, the United States Supreme Court decided Burrage v. United States, 571 U.S. 204, holding that, “at least where use of the drug distributed by the defendant is not an independently sufficient cause of the victim’s death or serious bodily injury, a defendant cannot be liable under the penalty enhancement provision of 21 U.S.C. § 841(b)(1)(C) unless such use is a but-for cause of the death or injury.” Id. at 218-19. Petitioner contends that he is actually innocent of the facts used for the § 841(b)(1) sentence enhancement under Burrage and thus may bring this petition under § 2255(e)’s “savings clause.” Respondent disputes that this court has jurisdiction over the matter. ECF No. 9 at 3-5. Significantly, respondent has produced evidence from petitioner’s sentencing that shows that petitioner’s sentence was not enhanced under the portion of § 841(b)(1)(C) that was addressed by Burrage, because there was no finding that petitioner had distributed drugs that contributed to someone’s death. United States v. Cruz Iniguez, C.D. Cal. Case No. 8:98-cr-00166-CJC, ECF No. 273 (transcript of petitioner’s October 28, 2005 sentencing hearing, hereinafter “Sentencing Transcript”) at 52-53, 56-60. Instead, petitioner’s sentence was enhanced under another provision in the same subsection (§ 841(b)(1)(C)) regarding prior convictions. Id. II. Jurisdictional Requirements Before it can reach the merits of the petition, the court is obligated to first determine whether it has jurisdiction over this § 2241 petition under § 2255(e)’s savings clause. Hernandez v. Campbell, 204 F.3d 861, 865-66 (9th Cir. 2000). United States District Courts have authority under 28 U.S.C. § 2241 to grant petitions for writ of habeas corpus to federal prisoners “in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2241(c). Ordinarily, a federal prisoner challenging his sentence must do so in a § 2255 motion in the sentencing court. Harrison v. Ollison, 519 F.3d 952, 954 (9th Cir. 2008). Section 2255(e) permits such challenge under § 2241, however, where a § 2255 motion would be “inadequate or ineffective to test the legality of his detention.” A § 2255 motion is “inadequate or ineffective” where the petitioner: (1) claims he is actually innocent and (2) has not had an unobstructed procedural shot at presenting the claim. Alaimalo v. United States, 645 F.3d 1042, 1047 (9th Cir. 2011). Courts have recently held that petitions challenging pre-Burrage enhancements under § 841(b)(1)(C) can meet both requirements. Harrington v. Ormond, 900 F.3d 246 (6th Cir. 2018); Terry v. Shartle, No. CV-15-00107-TUC-CKJ (EJM), 2017 U.S. Dist. LEXIS 78282 (D. Ariz. May 23, 2017). III. Analysis Respondent argues that this court lacks jurisdiction over the petition because petitioner fails to viably claim actual innocence and that petitioner has had multiple prior unobstructed procedural opportunities to challenge his sentence. The court must agree that jurisdiction is lacking. Petitioner’s claim of actual innocence rests entirely on Burrage. There, the U.S. Supreme reviewed 21 U.S.C. § 241(b)(1)(C), which provides, in relevant part:

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Related

Alaimalo v. United States
645 F.3d 1042 (Ninth Circuit, 2011)
Harrison v. Ollison
519 F.3d 952 (Ninth Circuit, 2008)
Burrage v. United States
134 S. Ct. 881 (Supreme Court, 2014)
Kurt Harrington v. J. Ray Ormond
900 F.3d 246 (Sixth Circuit, 2018)
Turner v. Duncan
158 F.3d 449 (Ninth Circuit, 1998)
Hernandez v. Campbell
204 F.3d 861 (Ninth Circuit, 2000)