(HC) Nguyen v. Arias

District Court, E.D. California·Decided October 24, 2024·No. 2:23-cv-01086·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 DAI NGUYEN, No. 2:23-cv-01086-DAD-JDP 12 Petitioner, 13 v. ORDER ADOPTING FINDINGS AND RECOMMENDATIONS, DISMISSING 14 ACEVEDO, PETITION FOR WRIT OF HABEAS CORPUS, AND DENYING MOTION TO 15 Respondent. APPOINT COUNSEL 16 (Doc. Nos. 9, 10, 14)

18 19 Petitioner Dai Nguyen is a state prisoner proceeding pro se and in forma pauperis with a 20 petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254. The matter was referred to a 21 United States Magistrate Judge pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 302. 22 On December 7, 2023, the assigned magistrate judge issued findings and 23 recommendations, recommending that the pending second amended petition for federal habeas 24 relief be dismissed without leave to amend for failure to state a cognizable claim for federal 25 habeas relief (Doc. No. 10 at 3), largely on the same grounds upon which the magistrate judge 26 previously dismissed petitioner’s original and first amended petitions (see Doc. Nos. 6, 8). 27 Specifically, the magistrate judge first concluded that because petitioner is seeking relief under 28 ///// 1 California Senate Bill 1437,1 an issue involving only the interpretation of state law, petitioner has 2 not stated a cognizable federal habeas claim (Doc. No. 10 at 1–2) (citing Lewis v. Jeffers, 497 3 U.S. 764, 780 (1990)), and that “petitioner’s attempts to recast the denial as a violation of his due 4 process rights by alleging that the state courts were ‘biased’ or ‘vindictive’ cannot save his claim” 5 (id.) (citing Langford v. Day, 110 F.3d 1380 (9th Cir. 1996)). Second, the magistrate judge 6 concluded that petitioner’s claims concerning the effectiveness of his counsel during the 7 resentencing proceedings did not present a cognizable federal habeas claim, either, because there 8 is no federal constitutional right to counsel in state postconviction resentencing proceedings 9 conducted under California Penal Code § 1170.95. (Id. at 2.) Third, the magistrate judge 10 concluded that petitioner’s claims concerning his underlying conviction, which occurred in 2000, 11 were untimely in light of the one-year statute of limitations imposed by the Antiterrorism and 12 Effective Death Penalty Act. (Id. at 2.) The magistrate judge further noted that “[t]here is, for 13 example, no basis on which to conclude that the denial under section 1170.95 restarted the statute 14 of limitations for the original, underlying conviction.” (Id. at 2–3.) 15 These findings and recommendations were served on all parties and contained notice that 16 any objections thereto were to be filed within fourteen (14) days of service, and that any response 17 to objections were to be filed within fourteen (14) days after service of the objections. (Id. at 3.) 18 Petitioner timely filed his objections on December 18, 2023. (Doc. No. 11.) 19 In his objections, petitioner largely repeats arguments and cites to case law that he 20 presented in his second amended petition and that the assigned magistrate judge already 21 considered and properly rejected. First, petitioner argues that the magistrate judge “did not make 22 a finding on petitioner[’s] claim [that] the sentence, or denial of resentencing[,] is arbitrary or 23 1 On September 30, 2018, then-California governor Brown signed Senate Bill No. 1437, which 24 amended California Penal Code §§ 188 and 189 and created Penal Code § 1170.95. The legislation limited accomplice liability in California for felony murder and murder under the 25 natural and probable consequences theory, and provided a petition procedure through which qualifying defendants could seek to vacate their murder convictions and obtain resentencing. The 26 amendments went into effect on January 1, 2019. See Cal. Const., art. IV, § 8(c). “Effective 27 June 30, 2022, Penal Code section 1170.95 was renumbered section 1172.6. The court continues to refer to this statute as section 1170.95 to be consistent with the petition.” Green v. Lovello, 28 No. 2:23-cv-07599-FMO-KES, 2023 WL 6613013, at *1 n.1 (C.D. Cal. Oct. 10, 2023). 1 capricious” and thereby violated petitioner’s due process rights under the Fourteenth Amendment. 2 (Id. at 1–4) (citing Richmond v. Lewis, 506 U.S. 40 (1992)); see also Richmond, 506 U.S. at 50 3 (“[T]he question to be decided by a federal court on petition for habeas corpus is not whether the 4 state sentencer committed state-law error . . . . Rather, the federal, constitutional question is 5 whether such reliance is ‘so arbitrary or capricious as to constitute an independent due process or 6 Eighth Amendment violation.’”). Petitioner further argues that “[t]he state courts clearly 7 show[ed] bias and vindictiveness” during his resentencing proceedings. (Id. at 3.) Petitioner’s 8 objections in this regard provide no basis upon which to decline to adopt the pending findings and 9 recommendations, in which the magistrate judge concluded, as discussed above, that “petitioner’s 10 attempts to recast the denial [of his resentencing petition] as a violation of his due process rights 11 by alleging that the state courts were ‘biased’ or ‘vindictive’ cannot save his claim.” (Doc. 12 No. 10 at 1–2); see also Green, 2023 WL 6613013, at *7–8 (“That Petitioner has invoked his 13 federal constitutional right to due process does not transform his state law claims into cognizable 14 federal claims”). 15 Second, petitioner argues that the magistrate judge, in recommending that petitioner’s 16 ineffective assistance of counsel claim be dismissed due to petitioner’s lack of a federal 17 constitutional right to counsel, failed to consider that “courts have ruled that denial of petition 18 [under] section 1170.95 is [a] new judgment,” such that petitioner did have a federal 19 constitutional right to counsel in those proceedings. (Doc. No. 11 at 4) (citing Magwood v. 20 Patterson, 561 U.S. 320 (2010); Gideon v. Wainwright, 372 U.S. 335 (1963); Douglas v. 21 California, 372 U.S. 353 (1963)). However, the Supreme Court’s decision in Magwood, cited by 22 petitioner, addressed whether a habeas petition was successive, see Magwood, 561 U.S. 320, and 23 does not support petitioner’s argument in this regard. As the magistrate judge noted in the 24 pending findings and recommendations, district courts in this circuit have routinely found that 25 there is no federal constitutional right to counsel in resentencing proceedings under § 1170.95. 26 (See Doc. No. 10 at 2); see, e.g., Hunt v. Cicnero, No. 2:22-cv-02472-JAK-KES, 2022 WL 27 17224722, at *7 (C.D. Cal. July 20, 2022) (“Resentencing proceedings under California Penal 28 Code section 1170.95 are the type of postconviction proceedings in which there is no federal 1 constitutional right to counsel.”), report and recommendation adopted, 2022 WL 17225020 (C.D. 2 Cal. Sept. 14, 2022). Petitioner’s objections therefore provide no basis upon which to decline to 3 adopt the findings and recommendation that petitioner’s ineffective assistance of counsel claim be 4 dismissed.

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Related

Douglas v. California
372 U.S. 353 (Supreme Court, 1963)
Richmond v. Lewis
506 U.S. 40 (Supreme Court, 1992)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Magwood v. Patterson
561 U.S. 320 (Supreme Court, 2010)
Gideon v. Wainwright
372 U.S. 335 (Supreme Court, 1963)