(HC) Jones v. Cates

CourtDistrict Court, E.D. California
DecidedDecember 30, 2024
Docket1:22-cv-00839
StatusUnknown

This text of (HC) Jones v. Cates ((HC) Jones v. Cates) 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) Jones v. Cates, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 STEPFON JONES, Case No. 1:22-cv-00839-JLT-HBK (HC) 12 Petitioner, FINDINGS AND RECOMMENDATIONS TO DISMISS PETITION AND DECLINE TO 13 v. ISSUE A CERTIFICATE OF APPEALABILITY 1 14 B. CATES, Warden, FOURTEEN-DAY OBJECTION PERIOD 15 Respondent. 16 17 18 I. STATUS 19 Petitioner Stepfon Jones (“Petitioner” or “Jones”), a state prisoner, is proceeding pro se on 20 his second amended petition for writ of habeas corpus filed under 28 U. S.C. § 2254 on 21 November 14, 2022. (Doc. No. 11, “Petition” or “Second Amended Petition”). Petitioner 22 challenges his judgment of conviction after a jury trial for (1) second degree murder in violation 23 of Penal Code § 187; (2) assault on a child under eight resulting in death in violation of Penal 24 Code § 273ab(a); and (3) child endangerment in violation of Penal Code § 273a(a). (Case No. 25 BF159975A). (Doc. No. 19-1 at 1034-37; Doc. No. 19-2 at 2587).2 The Second Amended 26 1 This matter was referred to the undersigned pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 302 27 (E.D. Cal. 2022). 2 All citations to the pleadings and record are to the page number as it appears on the Case Management 28 and Electronic Case Filing (“CM/ECF”) system. 1 Petition presents two (restated) grounds for relief: 2 (1) The use of CalCrim 200 violated clearly established federal law based on the Ninth 3 Circuit case Ho v. Carey, 332 F.3d 547 (9th Cir. 2003); and 4 (2) The use of CalCrim 200 eased the prosecutor’s burden to prove every element of an 5 offense beyond a reasonable doubt. 6 (See generally Doc. No. 11 at 5-7). On January 11, 2023, Respondent filed an Answer to the 7 Petition (Doc. No. 20) and lodged the state court record in support (Doc. No. 19, 19-1 through 19- 8 3). Respondent argues both grounds raised in the Second Amended Petition are procedurally 9 barred. (Doc. No. 20 at 8). Petitioner did not file a reply and the time to do so has expired. This 10 matter is deemed submitted on the record before the Court. After careful review of the record and 11 applicable law, the undersigned finds both grounds are procedurally defaulted and recommends 12 the district court dismiss the Second Amended Petition and decline to issue a certificate of 13 appealability. 14 II. PROCEDURAL HISTORY 15 After conviction, the Fifth Appellate District Court affirmed Jones’s judgment on direct 16 appeal. (Case No. F075895). (Doc. No. 19-2 at 2587-88). On December 30, 2020, the California 17 Supreme Court summarily denied Jones’s petition for review. (Case No. S265269). (Doc. No. 18 19-3 at 82). 19 On November 29, 2021, Petitioner filed a Petition for Writ of Habeas Corpus in the California 20 Supreme Court. (Case No. S272052). (Doc. No. 19-3 at 375, “State Petition”). Petitioner 21 asserted that (1) the trial court erred in giving California Criminal Instruction 200 (“CalCrim 22 200”) and (2) this instruction lowered the burden of proof required to support a conviction. (Id. at 23 380-83). On April 13, 2022, the California Supreme Court denied the State Petition citing to 24 In re Robbins, 18 Cal.4th 770, 780 (1998), and In re Dixon, 41 Cal.2d 756, 759 (1953). (Doc. 25 No. 19-3 at 395). 26 III. GOVERNING LEGAL PRINCIPLES 27 A. Evidentiary Hearing 28 “In deciding whether to grant an evidentiary hearing, a federal court must consider 1 whether such a hearing could enable an applicant to prove the petition's factual allegations, 2 which, if true, would entitle the applicant to federal habeas relief.” Schriro v. Landrigan, 550 3 U.S. 465, 474 (2007). “It follows that if the record refutes the applicant's factual allegations or 4 otherwise precludes habeas relief, a district court is not required to hold an evidentiary hearing.” 5 Id. Petitioner did not request an evidentiary hearing. This Court independently finds that the 6 pertinent facts of this case are fully developed in the record before the Court; thus, no evidentiary 7 hearing is required. Cullen v. Pinholster, 563 U.S. 170 (2011). 8 B. Procedural Default 9 A federal court’s statutory authority to issue habeas corpus relief for persons in state 10 custody is set forth in 28 U.S.C. § 2254, as amended by the Antiterrorism and Effective Death 11 Penalty Act of 1996 (AEDPA). AEDPA requires a state prisoner seeking federal habeas relief to 12 first “exhaus[t] the remedies available in the courts of the State.” 28 U.S.C. § 2254(b)(1)(A). “A 13 federal habeas claim is technically exhausted but procedurally defaulted if the state court declined 14 to address the claim based on independent and adequate state procedural grounds.” Rodney v. 15 Garrett, 116 F.4th 947, 954 (9th Cir. 2024) (citing Coleman v. Thompson, 501 U.S. 722, 729-32 16 (1991)). For a claim to be procedurally defaulted, the state procedural rule relied on must be “a 17 nonfederal ground adequate to support the judgment” and be “firmly established and consistently 18 followed.” Martinez v. Ryan, 566 U.S. 1, 9 (2012). Federal courts are generally prohibited from 19 reviewing procedurally defaulted claims. Coleman, 501 U.S. at 729-30. 20 “A state prisoner may overcome the prohibition on reviewing procedurally defaulted 21 claims if he can show ‘cause’ to excuse his failure to comply with the state procedural rule and 22 ‘actual prejudice resulting from the alleged constitutional violation.’” Davila v. Davis, 582 U.S. 23 521, 528 (2017). To establish “cause,” the petitioner must “show that some objective factor 24 external to the defense impeded counsel’s efforts to comply with the State’s procedural rule. A 25 factor is external to the defense if it ‘cannot fairly be attributed to’ the prisoner.” Id. (internal 26 citation omitted). “[T]o establish prejudice, the prisoner must show not merely a substantial 27 federal claim, such that the errors at trial created a possibility of prejudice, but rather that the 28 1 constitutional violation worked to his actual and substantial disadvantage.” Shinn v. Ramirez, 2 596 U.S. 366, 379-80 (2022) (internal quotation marks and alterations omitted). 3 A second exception, known as the fundamental miscarriage of justice, only occurs in an 4 extraordinary case, where a “constitutional violation has probably resulted in the conviction of 5 one who is actually innocent.” Murray v. Carrier, 477 U.S. 478, 496 (1986). Actual innocence 6 means factual innocence, not legal sufficiency. Bousley v. United States, 523 U.S. 614, 623 7 (1998). To meet this standard, a petitioner must “show that it is more likely than not that no 8 reasonable juror would have convicted him” of the underlying offense. Schlup v. Delo, 513 U.S. 9 298, 327 (1995). “To be credible, a claim of actual innocence must be based on [new] reliable 10 evidence not presented at trial.” Calderon v. Thompson, 523 U.S. 538, 559 (1998) (quoting 11 Schlup, 513 U.S. at 324). 12 IV.

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

Related

Sims Lessee v. Irvine
3 U.S. 425 (Supreme Court, 1799)
Murray v. Carrier
477 U.S. 478 (Supreme Court, 1986)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Calderon v. Thompson
523 U.S. 538 (Supreme Court, 1998)
Bousley v. United States
523 U.S. 614 (Supreme Court, 1998)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Walker v. Martin
131 S. Ct. 1120 (Supreme Court, 2011)
Martinez v. Ryan
132 S. Ct. 1309 (Supreme Court, 2012)
United States v. Rafat Asrar
116 F.3d 1268 (Ninth Circuit, 1997)
In Re Robbins
959 P.2d 311 (California Supreme Court, 1998)
In Re Dixon
264 P.2d 513 (California Supreme Court, 1953)
Austin v. United States
513 U.S. 5 (Supreme Court, 1994)
J. Wilkerson v. B. Wheeler
772 F.3d 834 (Ninth Circuit, 2014)
H. John Putnam v. Diane Keller
332 F.3d 541 (Eighth Circuit, 2003)
Johnson v. Lee
578 U.S. 605 (Supreme Court, 2016)
Microsoft Corp. v. Baker
582 U.S. 23 (Supreme Court, 2017)
Shinn v. Martinez Ramirez
596 U.S. 366 (Supreme Court, 2022)
Cullen v. Pinholster
179 L. Ed. 2d 557 (Supreme Court, 2011)
Kyle Rodney v. Tim Garrett
116 F.4th 947 (Ninth Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
(HC) Jones v. Cates, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hc-jones-v-cates-caed-2024.