(HC) Mosier v. Honea

CourtDistrict Court, E.D. California
DecidedJanuary 21, 2025
Docket2:24-cv-02282
StatusUnknown

This text of (HC) Mosier v. Honea ((HC) Mosier v. Honea) 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) Mosier v. Honea, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 CHAD NOLEN MOSIER, No. 2:24-cv-2282-CKD P 12 Petitioner, 13 v. ORDER 14 KOREY HONEA, 15 Respondent.

16 17 Petitioner Chad Nolen Mosier, a county inmate, filed a petition for writ of habeas corpus 18 pursuant to 28 U.S.C. § 2254. On October 18, 2024, the court screened the petition, found its 19 allegations were too vague to specify any constitutional violation entitling petitioner to relief, and 20 dismissed the petition with leave to amend. (ECF No. 4.) The amended petition is before the court 21 for screening. (ECF No. 5.) 22 I. Screening Standard 23 In screening the habeas petition, the court applies the Rule 4 framework of the Rules 24 Governing Section 2254 Cases in the United States District Courts. Under Rule 4’s standard, if it 25 plainly appears from the petition, any attached exhibits, and the record of prior proceedings that 26 the moving party is not entitled to relief, then the district court is authorized to summarily dismiss 27 a habeas petition. Neiss v. Bludworth, 114 F.4th 1038, 1044 (9th Cir. 2024); Herbst v. Cook, 260 28 F.3d 1039, 1043 (9th Cir. 2001). 1 II. Allegations in the Amended Petition 2 Petitioner challenges a judgment of conviction in the Butte County Superior Court entered 3 on June 17, 2024. (ECF No. 5 at 1.) He first brings a claim regarding jail conditions, alleging the 4 food ports in B-Pod and A-Pod are not secure. (Id. at 4.) Petitioner next asserts there is “wrong 5 information in the court’s paperwork, such as a wrong address and wrong dates.” (Id.) In ground 6 three, petitioner alleges incompetence of counsel, who allegedly threatened petitioner because he 7 would not take a deal. (Id. at 5.) Finally, petitioner asserts “attorney abandonment” in that his 8 attorneys have failed to represent him twice while he has been in custody. (Id.) 9 According to the amended petition’s allegations, petitioner did not appeal from the 10 judgment of conviction. (ECF No. 5 at 1.) The only other petition, application, or motion filed 11 with respect to the judgment of conviction is a use of force claim raised in the Butte County 12 Superior Court. (Id. at 2.) 13 III. Discussion 14 A. Insufficient Factual Allegations 15 Petitioner has not remedied the defects identified in the court’s initial screening order. In 16 the court’s initial screening order, the court found petitioner failed to specify a constitutional 17 violation entitling him to relief based on the following asserted grounds: 18 First, [petitioner] asserts that his arrest was late. Next, petitioner contends that a Chico police officer lied about petitioner going 19 through drawers at the crime scene. Petitioner also asserts that he was discriminated against in the community on two occasions. 20 Lastly, petitioner believes that an officer behaved improperly by asking him if he was homeless. 21 22 (ECF No. 4 at 1-2.) 23 The amended petition, while appearing to raise some different grounds for relief, suffers 24 from the same deficiencies described in that order because it sets forth a mere sentence or two for 25 each ground. More detailed factual allegations are required to state a claim. 26 Habeas Rule 2(c) requires that a petition (1) specify all grounds of relief available to the 27 petitioner; (2) state the facts supporting each ground; and (3) state the relief requested. Notice 28 pleading is not sufficient; rather, the petition must state facts that point to a real possibility of a 1 constitutional error. Mayle v. Felix, 545 U.S. 644, 655 (2005). Allegations in a petition that are 2 vague, conclusory, or palpably incredible are subject to summary dismissal. Hendricks v. 3 Vasquez, 908 F.2d 490, 491 (9th Cir. 1990). 4 Although the court understands petitioner to be asserting ineffective assistance of counsel, 5 petitioner has not provided the necessary supporting facts for any claim and therefore has not 6 specified a constitutional violation entitling him to relief. The amended petition must be 7 dismissed. 8 B. Scope of Habeas Jurisdiction 9 Petitioner’s first ground for relief challenging jail conditions is outside the scope of this 10 court’s jurisdiction for a petition under 28 U.S.C. § 2254. Habeas jurisdiction extends only to 11 claims challenging the validity or duration of a prisoner’s confinement. See generally Muhammad 12 v. Close, 540 U.S. 749, 750 (2004); Dominguez v. Kernan, 906 F.3d 1127, 1137 (9th Cir. 2018). 13 In contrast, issues related solely to the conditions of an inmate’s confinement, which do not 14 directly affect the fact of duration of custody, must be pursued in a civil rights action. See Nettles 15 v. Grounds, 830 F.3d 922, 930 (9th Cir. 2016) (“§ 1983 is the exclusive remedy for state prisoner 16 claims that do not lie at the core of habeas”); id. at 935 (9th Cir. 2016) (claims that if successful 17 would not necessarily lead to immediate or earlier release from confinement do not fall within the 18 core of habeas corpus). 19 Because success on petitioner’s claim regarding food ports at the jail could not lead to his 20 immediate or speedier release from custody, ground one of the amended petition is outside the 21 core of habeas corpus. Such a claim cannot be pursued in habeas petition and must, instead, be 22 pursued in a civil rights action under 42 U.S.C. § 1983. See id. at 927-28. 23 C. Exhaustion Requirement 24 The amended petition also fails to show petitioner exhausted state judicial remedies. A 25 petitioner who wishes to collaterally challenge his state convictions by a petition for writ of 26 habeas corpus must exhaust state judicial remedies. 28 U.S.C. § 2254(b)(1). Although non- 27 exhaustion of remedies has been viewed as an affirmative defense, it is the petitioner’s burden to 28 prove that state judicial remedies were properly exhausted. 28 U.S.C. § 2254(b)(1)(A), and the 1 court may raise the exhaustion issue sua sponte. Cartwright v. Cupp, 650 F.2d 1103, 1104 (9th 2 Cir. 1981). 3 A petitioner can satisfy the exhaustion requirement by providing the highest state court 4 with the necessary jurisdiction a fair opportunity to consider each claim before presenting it to the 5 federal court, and by demonstrating that no state remedy remains available. Picard v. Connor, 404 6 U.S. 270, 275 (1971); Ybarra v. McDaniel, 656 F.3d 984, 991 (9th Cir. 2011). When none of a 7 petitioner’s claims have been presented to the highest state court, the court should ordinarily 8 dismiss the petition. Rasberry v. Garcia, 448 F.3d 1150, 1154 (9th Cir. 2006) (“Once a district 9 court determines that a habeas petition contains only unexhausted claims ... it may simply dismiss 10 the habeas petition for failure to exhaust.”).

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Bluebook (online)
(HC) Mosier v. Honea, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hc-mosier-v-honea-caed-2025.