Heim v. Gamboa

CourtDistrict Court, S.D. California
DecidedJanuary 8, 2025
Docket3:24-cv-02476
StatusUnknown

This text of Heim v. Gamboa (Heim v. Gamboa) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heim v. Gamboa, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JACOB DANIEL HEIM, Case No.: 24-cv-02476-AJB-DEB

12 Petitioner, ORDER: 13 v. (1) GRANTING MOTION TO PROCEED 14 M. GAMBOA, Warden, et al., IN FORMA PAUPERIS; AND 15 Respondents. (2) NOTIFYING PETITIONER OF 16 OPTIONS TO AVOID DISMISSAL OF 17 PETITION

18 [ECF Nos. 1, 2] 19 20 Petitioner, a state prisoner proceeding pro se, has filed a Petition for Writ of Habeas 21 Corpus pursuant to 28 U.S.C. § 2254, challenging a 2022 San Diego County Superior Court 22 conviction in case number SCD290089. (ECF No. 1.) Petitioner has also filed a motion for 23 leave to proceed in forma pauperis. (ECF No. 2.) For the reasons discussed, the Court 24 GRANTS the motion to proceed in forma pauperis and NOTIFIES Petitioner of his 25 options to avoid a future dismissal of the instant habeas action. 26 REQUEST TO PROCEED IN FORMA PAUPERIS 27 Petitioner has $0.00 on account at the California correctional institution in which he 28 is presently confined (see ECF No. 2 at 4, 6), and cannot afford the $5.00 filing fee. 1 Accordingly, the Court GRANTS Petitioner’s motion to proceed in forma pauperis and 2 allows him to prosecute the above-referenced action without being required to prepay fees 3 or costs and without being required to post security. The Clerk of Court will file the Petition 4 without prepayment of the filing fee. 5 FAILURE TO EXHAUST STATE COURT REMEDIES 6 Upon review, it does not appear state court remedies have been exhausted as to any 7 of the sixteen enumerated claims in the Petition. Habeas petitioners who wish to challenge 8 either their state court conviction or the length of their confinement in state prison must 9 first exhaust state judicial remedies. See 28 U.S.C. § 2254(b), (c); Granberry v. Greer, 481 10 U.S. 129, 133–34 (1987); see also Picard v. Connor, 404 U.S. 270, 275 (1971) (“[A] state 11 prisoner must normally exhaust available state judicial remedies before a federal court will 12 entertain his petition for habeas corpus.”). “A petitioner has satisfied the exhaustion 13 requirement if: (1) he has ‘fairly presented’ his federal claim to the highest state court with 14 jurisdiction to consider it,” which in this case is the California Supreme Court, “or (2) he 15 demonstrates that no state remedy remains available.” Johnson v. Zenon, 88 F.3d 828, 829 16 (9th Cir. 1996) (citations omitted); see also O’Sullivan v. Boerckel, 526 U.S. 838, 845 17 (1999) (“[S]tate prisoners must give the state courts one full opportunity to resolve any 18 constitutional issues by invoking one complete round of the State’s established appellate 19 review process.”). 20 Additionally, the claims presented in the federal courts must be the same as those 21 exhausted in state court and a petitioner must also allege, in state court, how one or more 22 of his federal rights have been violated. See Picard, 404 U.S. at 276 (“Only if the state 23 courts have had the first opportunity to hear the claim sought to be vindicated in a federal 24 habeas proceeding does it make sense to speak of the exhaustion of state remedies. 25 Accordingly, we have required a state prisoner to present the state courts with the same 26 claim he urges upon the federal courts.”); see also Duncan v. Henry, 513 U.S. 364, 365– 27 66 (1995) (“If state courts are to be given the opportunity to correct alleged violations of 28 prisoners’ federal rights, they must surely be alerted to the fact that the prisoners are 1 asserting claims under the United States Constitution. If a habeas petitioner wishes to claim 2 that an evidentiary ruling at a state court trial denied him the due process of law guaranteed 3 by the Fourteenth Amendment, he must say so, not only in federal court, but in state 4 court.”). 5 Of the sixteen claims presented in his federal Petition, Petitioner indicates he has not 6 raised any of these claims in the California Supreme Court. (See ECF No. 1 at 6–24.) 7 Petitioner has attached a copy of the California Supreme Court’s denial of his petition for 8 review (see ECF No. 1-8 at 33), but he does not indicate that any of the claims in the instant 9 federal Petition were presented in that petition. Petitioner indicates that he did not seek 10 collateral review in state court. (See ECF No. 1 at 3–4.) 11 In Rose v. Lundy, 455 U.S. 509 (1982), the United States Supreme Court held that a 12 petition which did not contain only exhausted claims is subject to dismissal because it 13 violates the “total exhaustion rule” required in habeas petitions brought pursuant to § 2254, 14 but that a petitioner must be permitted an opportunity to cure that defect prior to dismissal. 15 Id. at 514–20. Because the one-year statute of limitations imposed on section 2254 habeas 16 petitions after Lundy was decided created a risk of a claim dismissed under Lundy 17 becoming time-barred, the Supreme Court subsequently approved of a procedure by which 18 a federal Petition could be stayed while a petitioner returned to state court to exhaust. See 19 Rhines v. Weber, 544 U.S. 269, 277–78 (2005); see also Mena v. Long, 813 F.3d 907, 912 20 (9th Cir. 2016) (“[A] district court has the discretion to stay and hold in abeyance fully 21 unexhausted petitions under the circumstances set forth in Rhines.”). The Supreme Court 22 has instructed “stay and abeyance should be available only in limited circumstances” and 23 was appropriate where: (1) “there was good cause for the petitioner’s failure to exhaust his 24 claims first in state court,” (2) the “unexhausted claims are potentially meritorious” and 25 (3) “there is no indication that the petitioner engaged in intentionally dilatory litigation 26 tactics.” Rhines, 544 U.S. at 277–78. 27 The Court now notifies Petitioner of his options to avoid a future dismissal for 28 presenting a petition with only unexhausted claims, with a deadline set forth below. 1 I. First Option: Demonstrate Exhaustion 2 Petitioner may file papers in which he alleges he has exhausted the claims in the 3 Petition. If Petitioner chooses this option, these papers are due no later than March 10, 4 2025. 5 II. Second Option: Voluntarily Dismiss the Petition 6 Petitioner may move to voluntarily dismiss his entire federal petition and return to 7 state court to exhaust his unexhausted claims. Petitioner may then file a new federal petition 8 containing only exhausted claims. 9 Petitioner is cautioned that any new federal petition must be filed before expiration 10 of the one-year statute of limitations. Ordinarily, a petitioner has one year from when his 11 conviction became final to file his federal petition, unless he can show that statutory or 12 equitable “tolling” applies. Duncan v. Walker, 533 U.S. 167, 176 (2001); 28 U.S.C. 13 § 2244(d).1 The statute of limitations does not run while a properly filed state habeas corpus 14 petition is pending. 28 U.S.C. § 2244(d)(2); see also Nino v.

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Related

Fletcher v. Peck
10 U.S. 87 (Supreme Court, 1810)
Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Artuz v. Bennett
531 U.S. 4 (Supreme Court, 2000)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Samuel Quinton Bonner v. Tom Carey, Warden
425 F.3d 1145 (Ninth Circuit, 2005)
Samuel Quinton Bonner v. Tom Carey, Warden
439 F.3d 993 (Ninth Circuit, 2006)
Duncan v. Henry
513 U.S. 364 (Supreme Court, 1995)
Armando Mena v. David Long
813 F.3d 907 (Ninth Circuit, 2016)

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Bluebook (online)
Heim v. Gamboa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heim-v-gamboa-casd-2025.