(HC) Murphy v. Attorney General of California

District Court, E.D. California·Decided June 10, 2020·No. 2:19-cv-02546·Unknown

Opinion

JOSHUA MURPHY, No. 2:19-cv-02546 KJM GGH P Petitioner, v. ORDER AND FINDINGS AND RECOMMENDATIONS CALIFORNIA, Respondent.

Introduction and Summary Petitioner, a former state prisoner proceeding pro se, has filed a petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254. The matter was referred to the United States Magistrate Judge pursuant to 28 U.S.C. § 636(b)(1) and Local Rule 302(c). Petitioner has filed a petition for habeas corpus relief with respect to his conviction for possession of a large capacity magazine (Cal. Penal Code § 32310) and possession of child pornography (Cal. Penal Code § 311.11(a)). Petitioner initially received a sentence of four years of probation. See People v. Murphy, No. C084178, 2019 WL 1235623 (Cal. Ct. App. Mar. 18, 2019) (“Murphy 1”). He was later found to have violated conditions of his probation. “The trial court terminated probation, sentenced defendant to two years eight months in state prison, imposed various fines and fees, and awarded 141 days of presentence credit (71 actual and 70 conduct).” People v. Murphy, No. C084973, 2019 WL 1234939, at *1 (Cal. Ct. App. Mar. 18, 2019) (“Murphy 2”). In the Answer, respondent contests the jurisdiction of this court over the petition and personal jurisdiction over the respondent, the exhaustion of all claims, and finally, in the alternative, respondent contests the merits of the petition. ECF No. 18. For the reasons that follow, the undersigned finds that jurisdiction exists, but cannot find that petitioner has exhausted all issues (or even any issues he raises now) before the California Supreme Court. Subject Matter Jurisdiction Conflating the “in custody” analysis with an element of mootness (the inability to grant relief), respondent agrees that petitioner was in custody at the time of the petition’s filing and that the case is not moot, but nevertheless contests the standing of petitioner to bring this petition. See ECF No. 12 at 1, 7, 8. 1. Facts The facts of the felonies themselves are not germane at this point—just the essential, procedural facts for this protracted, convoluted prosecution. Petitioner was initially arrested in 2013 for the felony weapons and pornography charges. The defendant vacillated between defending himself, having counsel and then having the “right” counsel. All of the pre-trial permutations are not relevant to the jurisdictional analysis. Petitioner ultimately pled “no contest” in October of 2016. ECF No. 13-28 at 54-64.1 He was sentenced to four years of probation on February 16, 2017. ECF No. 13-28 at 153-162; 168- 173 (terms of probation). An appeal was taken on February 23, 2017, ostensibly on post-plea grounds and not on the validity of the plea. ECF No. 13-28 at 174. However, the appeal did involve the validity of the search warrants as well as their execution. See ECF No. 13-2 at 1-43. During the pendency of that appeal, petitioner violated the terms of his probation. Probation was terminated and he was ultimately sentenced to prison subject to Post Release Community Supervision. ECF No. 13-34 at 66-73. One of the conditions upon his release was for 1 The undersigned uses the e-page numbers for the CM/ECF filing system for ease and consistency of reference. petitioner to register as a sex offender pursuant to Cal. Penal Code § 290. Id. at 69. There is nothing in the record to demonstrate that petitioner has ever been relieved of that requirement. An appeal was taken for the probation revocation on June 16, 2017. ECF No. 13-34 at 75; see also ECF Nos. 8, 9, 10. Both appeals were decided in separate opinions on the same day, March 18, 2019, adversely to petitioner, by the Court of Appeal as referenced in the Introduction and Summary above. Petitions for review filed with the California Supreme Court were fruitless. All concede that the Post Release Community Supervision (erroneously termed “probation” by respondent) terminated on December 24, 2019, less than one week after the filing of this federal petition. ECF No. 13-1. The federal petition filed on December 18, 2019 contained four grounds. ECF No. 1. Ground 4 was previously dismissed by this court as it did not relate to petitioner’s convictions. See ECF Nos. 4, 8. Grounds 1, 2, and perhaps 3 of the federal petition focus on the initial conviction for the felonies, and not the probation revocation itself. Ground 3 generally ascribes ineffective assistance to petitioner’s trial court and appellate attorneys, but the one specification of that asserted ineffectiveness was error regarding the issuance of the search warrants. 2. In Custody Respondent argues that because petitioner was relieved of all custody during the pendency of this federal petition, there is no relief available to petitioner; hence, petitioner is not “in custody.” However, the “in custody” analysis is separate and apart from whether any effective relief can be granted (mootness issue), and respondent’s jurisdictional argument based upon the present lack of custodial status must fail. The District Court’s conclusion that Spencer’s release from prison caused his petition to be moot because it no longer satisfied the “in custody” requirement of the habeas statute was in error. Spencer was incarcerated by reason of the parole revocation at the time the petition was filed, which is all the “in custody” provision of 28 U.S.C. § 2254 requires. See Carafas v. LaVallee, 391 U.S. 234, 238, 88 S.Ct. 1556, 1559–60, 20 L.Ed.2d 554 (1968); Maleng v. Cook, 490 U.S. 488, 490–491, 109 S.Ct. 1923, 1924–25, 104 L.Ed.2d 540 (1989) (per curiam). The more substantial question, however, is whether petitioner’s subsequent release caused the petition to be moot because it no longer presented a case or controversy under Article III, § 2, of the Constitution. “This case-or-controversy requirement subsists through all stages of federal judicial proceedings, trial and appellate.... The parties must continue to have a ‘personal stake in the outcome’ of the lawsuit.” Lewis v. Continental Bank Corp., 494 U.S. 472, 477–478, 110 S.Ct. 1249, 1254, 108 L.Ed.2d 400 (1990). See also Preiser v. Newkirk, 422 U.S. 395, 401, 95 S.Ct. 2330, 2334–35, 45 L.Ed.2d 272 (1975). This means that, throughout the litigation, the plaintiff “must have suffered, or be threatened with, an actual injury traceable to the defendant and likely to be redressed by a favorable judicial decision.” Lewis, supra, at 477, 110 S.Ct., at 1253. Spencer v. Kemna, 523 U.S. 1, 7 (1998) (emphasis added). See also Wenzel v. People of California, No. 06-0224-FMC MLG, 2006 WL 2917577, at *2-3 (C.D. Cal. June 29, 2006) (declining to find its petitioner “in custody,” but with an explanation that points to “in custody” in this case). However, there is one more custody issue here—although there is no doubt that petitioner was “in custody” at the time of this petition’s filing (Post Release Community Supervision had not been terminated then), was petitioner “in custody” for the purpose of attacking his previous “no contest” plea and subsequent sentencing to probation. Spencer does not answer that question as only the parole revocation was at issue there. In Zichko v. Idaho, 247 F. 3d 1015, 1019-1020 (9th Cir. 2001), the Ninth Circuit held: We now hold that a habeas petitioner is “in custody” for the purposes of challe

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

(HC) Murphy v. Attorney General of California, (E.D. Cal. 2020).

(HC) Murphy v. Attorney General of California ((HC) Murphy v. Attorney General of California) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Bailey v. Hill
599 F.3d 976 (Ninth Circuit, 2010)
Carafas v. LaVallee
391 U.S. 234 (Supreme Court, 1968)
Sibron v. New York
392 U.S. 40 (Supreme Court, 1968)
Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Intercounty Constraction Corp. v. Walter
422 U.S. 1 (Supreme Court, 1975)
Preiser v. Newkirk
422 U.S. 395 (Supreme Court, 1975)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Castille v. Peoples
489 U.S. 346 (Supreme Court, 1989)
Maleng v. Cook
490 U.S. 488 (Supreme Court, 1989)
Lewis v. Continental Bank Corp.
494 U.S. 472 (Supreme Court, 1990)
Spencer v. Kemna
523 U.S. 1 (Supreme Court, 1998)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Rumsfeld v. Padilla
542 U.S. 426 (Supreme Court, 2004)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
United States v. Juvenile Male
177 L. Ed. 2d 64 (Supreme Court, 2010)
Jose S. Chacon v. Tana Wood
36 F.3d 1459 (Ninth Circuit, 1994)