(HC) Jackson v. Biter

District Court, E.D. California·Decided October 27, 2021·No. 2:14-cv-02268·Unknown

Opinion

RACARDO JACKSON, No. 2:14-cv-2268 MCE DB P Petitioner, v. FINDINGS AND RECOMMENDATIONS Respondent. Petitioner is a state prisoner proceeding through counsel with a petition for a writ of habeas corpus under 28 U.S.C. § 2254. Presently before the court is respondent’s motion for stay of the District Court’s order granting petitioner’s petition for writ of habeas corpus. (ECF No. 72.) For the reasons set forth below, the court will recommend that the motion be granted. I. Background The undersigned issued findings and recommendations on the merits of petitioner’s § 2254 petition on June 29, 2020. (ECF No. 59.) Therein, it was recommended that the petition be granted on the bases that: (1) the prosecutor’s questions and argument regarding petitioner’s post- Miranda silence violated petitioner’s Fifth Amendment rights, and (2) petitioner’s Sixth Amendment right to the effective assistance of counsel was violated by his trial attorney’s failure to object to the prosecutor’s questions and argument regarding petitioner’s silence. (Id.) The findings and recommendations were adopted on March 18, 2021. (ECF No. 64.) The parties stipulated that respondent would release petitioner from custody unless the state commenced retrial proceedings within ninety days. (ECF Nos. 66, 70.) Thereafter, respondent filed a notice of appeal (ECF No. 67) and the instant motion seeking a stay of the order granting the petition (ECF No. 72). Petitioner has filed an opposition (ECF No. 73) and respondent has filed a reply (ECF No. 74). II. Motion for Stay Respondent seeks a stay of the district court’s March 18, 2021 order granting petitioner’s petition for writ of habeas corpus pending resolution of the appeal. (ECF No. 72.) In support of the motion respondent argues: (1) they have a substantial case on the merits because the court’s ruling was based on, Hurd v. Terhune, 619 F.3d 1080 (9th Cir. 2010), which respondent argues is no longer valid and/or should be overturned (Id. at 2-6); (2) a stay would prevent the state from having to expend resources that may be rendered moot following the appeal (Id. at 7-9); and (3) petitioner will not suffer injury by the delay (Id. at 9). In the opposition, petitioner argues the state is required to make a strong showing, the court relied on clearly established law in reaching its decision on the merits, and there is no risk to the state if it is forced to retry the case. (ECF No. 73.) In the reply, respondent argues that petitioner has mischaracterized Hurd in the opposition. (ECF No. 74 at 2.) Specifically, respondent disagrees with the characterization that there is a clearly established Supreme Court precedent applicable to the facts of the instant case. (Id. at 3.) Respondent argues that while the findings and recommendations noted this court “found itself ‘bound’ by Hurd,” it should be overturned in light of Supreme Court rulings issued after Hurd was decided. (ECF No. 74 at 2.) Respondent further argues the Ninth Circuit reached its decision in Hurd by “transposing Doyle v. Ohio, 426 U.S. 610 (1976)] into a context the Supreme Court had never addressed.” (ECF No. 74 at 4.) III. Legal Standards A district court retains jurisdiction over orders regarding a petitioner’s release from custody even after an appeal of the grant or denial of habeas relief has been processed. Stein v. Wood, 127 F.3d 1187, 1190 (9th Cir. 1997). There is a presumption of release from custody, however that presumption may be overcome “if the judge rendering the decision, or an appellate court or judge, ‘otherwise orders.’” Hilton v. Braunskill, 481 U.S. 770, 774 (1987) (citing Federal Rules of Appellate Procedure Rule 23(c)). Additionally, the “district court has broad discretion in conditioning a judgment granting habeas relief, including whether or not to release a prisoner pending appeal.” Stein, 127 F.3d at 1190. The Supreme Court indicated that “general standards governing stay of civil judgments” should guide a court when considering a request for stay. Hilton, 481 U.S. at 776. In deciding whether to exercise its discretion to grant a stay the court considers: “(1) whether the stay applicant has made a strong showing that he is likely to succeed on the merits; (2) whether the applicant will be irreparably injured absent a stay; (3) whether issuance of the stay will substantially injure the other parties interested in the proceeding; and (4) where the public interest lies.” Id. “Where the State establishes that it has a strong likelihood of success on appeal, or where, failing that, it can nonetheless demonstrate a substantial case on the merits, continued custody is permissible if the second and fourth factors in the traditional stay analysis militate against release.” Hilton, 481 U.S. at 778. “Where the State’s showing on the merits falls below this level, the preference for release should control.” Id. IV. Analysis A. Likelihood of Success on the Merits Respondent argues that the Ninth Circuit’s opinion in Hurd v. Terhune, 619 F.3d 1080 (9th Cir. 2010) “is no longer valid and/or should be overturned.” (ECF No. 72 at 3.) Respondent claims that Hurd extended the Supreme Court’s holding in Doyle v. Ohio, “far beyond its context.” (Id.) Respondent further argues that this case is distinguishable from Doyle because petitioner did not remain silent after receiving Miranda warnings. (Id.) Respondent further argues that the undersigned’s reliance on circuit authority in the findings and recommendations indicates that there is lack of clearly established Supreme Court precedent on the subject of selective invocation. (Id. at 6.) Respondent claims that they have a strong case for success on the merits regarding the issue of prejudice. (Id.) Petitioner argues that the selective silence is implicit in the Supreme Court’s decisions in Doyle and Miranda v. Arizona, 384 U.S. 436 (1966). (ECF No. 73 at 4-5.) Petitioner further claims it is not reasonable to think the state has any likelihood of success on appeal. (Id. at 7.) As stated in the June 29, 2020 findings and recommendations, whether petitioner’s rights were violated is a close call. (ECF No. 59 at 40.) The findings and recommendations also noted that there is a split of authority regarding proper application of Doyle. (Id. at 28.) Thus, respondent has shown that reasonable jurists may disagree with this court’s analysis of petitioner’s claim. Accordingly, the undersigned finds respondent has a substantial case on the merits. B. Irreparable Injury to the State Respondent argues that absent a stay, the state would have to retry petitioner during the pendency of the appeal. (ECF No. 72 at 7.) Respondent claims that due to the amount of time that has passed it may be difficult to locate witnesses and evidence. (Id.) Additionally, absent a stay, the state would be required to release petitioner if retrial proceedings cannot be commenced within ninety days. (Id.) Petitioner argues that he is in custody based on an unconstitutional conviction, retrial is not certain, and it is likely the case will ultimately resolve far short of the sentence petitioner is presently serving. (ECF No. 73 at 8.) Retrial would require substantial effort and use of public resources to contact witnesses and evidence potentially before the court of appeals reaches a final decision.

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Doyle v. Ohio
426 U.S. 610 (Supreme Court, 1976)
Hilton v. Braunskill
481 U.S. 770 (Supreme Court, 1987)
Hurd v. Terhune
619 F.3d 1080 (Ninth Circuit, 2010)
Franklin v. Duncan
891 F. Supp. 516 (N.D. California, 1995)