Herbert O Allen v. Allex Villanueva

District Court, C.D. California·Decided January 18, 2023·No. 2:22-cv-06000·Unknown

Opinion

Case 2:22-cv-06000-GW-GJS Document 9 Filed 01/18/23 Page 1 of 11 Page ID #:56 HERBERT O. ALLEN, Case No. 2:22-cv-06000-GW (GJS) Petitioner v. ORDER: SUMMARILY DISMISSING PETITION ALLEX VILLANUEVA, WITHOUT PREJUDICE; AND DENYING A CERTIFICATE OF Respondent. APPEALABILITY On August 22, 2022, Petitioner – a state pretrial detainee – filed a habeas petition pursuant to 28 U.S.C. § 2241 [Dkt. 1, “Petition”].1 The Petition names the former Sheriff for Los Angeles County as Respondent, raises four claims, and seeks Section 2241 habeas relief with respect to a pending criminal case, namely, Los Angeles County Superior Court Case No. BA494948 (the “Pending Criminal Case”). The Court has reviewed the Petition and, pursuant to Federal Rule of Evidence 201, has taken judicial notice of the relevant dockets for the California courts available electronically. 1 The Clerk’s Office docketed the Petition as one brought pursuant to 28 U.S.C. § 2254. As discussed infra, the Petition properly was brought under Section 2241, rather than under Section 2254. Case 2:22-cv-06000-GW-GJS Document 9 Filed 01/18/23 Page 2 of 11 Page ID #:57

Section 2241 habeas petitions may be subjected to the same screening requirements that apply to Section 2254 habeas petitions. Rule 1(b) of the Rules Governing Section 2254 Cases in the United States District Courts, 28 U.S.C. foll. § 2254 (“Habeas Rules”), provides that this Court may “apply any or all of these rules” to any habeas petition. Habeas Rule 4 requires that a district court dismiss a petition without ordering a responsive pleading when “it plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief.” See Mayle v. Felix, 545 U.S. 644, 656 (2005). The Advisory Committee Notes to Habeas Rule 4 (1976 Adoption) make clear that “it is the duty of the court to screen out frivolous applications and eliminate the burden that would be placed on the respondent by ordering an unnecessary answer,” particularly where the petition does not state facts “that point to a real possibility of constitutional error.” See also Bostic v. Carlson, 884 F.2d 1267, 1269-70 (9th Cir. 1989) (affirming district court's dismissal of a Section 2241 petition under Habeas Rules 1(b) and 4); Local Rule 72- 3.2 (authorizing magistrate judge to prepare for district judge proposed order for summary dismissal and proposed judgment if it plainly appears from the face of the habeas petition that the petitioner is not entitled to relief). The same is true under 28 U.S.C. § 2243, which provides that a district court may summarily dismiss a Section 2241 petition where “it appears from the application that the applicant or person detained is not entitled” to relief. See Ruby v. United States, 341 F.2d 585, 586-87 (9th Cir.1965) (affirming summary dismissal of Section 2241 petition that failed to show any basis for habeas relief and holding a district court is not required to construe such a petition as some other form of civil action and must deny the petition without speculating “whether or not it might be amended or supplemented to invoke the court’s jurisdiction to grant some other remedy”). Having screened the Petition pursuant to these provisions. the Court finds that summary dismissal of this action, without prejudice, is required pursuant to the abstention doctrine. 2 Case 2:22-cv-06000-GW-GJS Document 9 Filed 01/18/23 Page 3 of 11 Page ID #:58

The dockets for the Los Angeles County Superior Court show that the Pending Criminal Case stems from eight charges brought against Petitioner, including charges of attempted murder, a charges of assault with a deadly weapon, a charge of unlawful use of tear gas, and charges based on Petitioner being a felon in possession of a firearm and ammunition. An arraignment was scheduled for April 20, 21, 22, and 23, 2021, and concluded on April 26, 2021 – the date on which Petitioner alleges he was arraigned. The preliminary hearing occurred late last year, and on November 2, 2022, Petitioner was held to answer on all charges. A pretrial hearing is set for January 2023. Thus, the record shows that Petitioner has not yet been convicted in connection with the pending state court criminal action on which the Petition rests. As discussed below, the Petition alleges four claims. Petitioner alleges that he raised three of them in a habeas petition filed with the California Court of Appeal, which was denied,2 and that he then filed a habeas petition in the California Supreme Court (claims unspecified), which was denied on June 29, 2022. Thus, it is unclear whether or not the Petition is fully exhausted. Ground One of the Petition rests on the theory that Petitioner’s Fourth Amendment rights were violated due to a delay in his arraignment. Petitioner alleges that he was arrested on April 18, 2021, but was not arraigned until April 26, 2021, instead of within 48 hours. Petitioner contends that this delay deprives the state courts of jurisdiction over the Pending Criminal Case. 2 The Petition attaches copies of two Orders issued by the California Court of Appeal: one dated June 15, 2022, in Case No. B320921, summarily denying a mandamus petition filed on June 13, 2022; and the other dated July 20, 2022, in Case No. B321625, denying a mandamus petition filed in the Supreme Court on July 14, 2022, and then transferred to the state appellate court. 3 Case 2:22-cv-06000-GW-GJS Document 9 Filed 01/18/23 Page 4 of 11 Page ID #:59

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