Hoadena Ingram v. Habeas Corpus

CourtDistrict Court, C.D. California
DecidedAugust 11, 2020
Docket5:20-cv-01527
StatusUnknown

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

Bluebook
Hoadena Ingram v. Habeas Corpus, (C.D. Cal. 2020).

Opinion

CIVIL MINUTES – GENERAL

Case No.: 5:20-cv-01527-JVS-MAA Date: August 11, 2020 Title: Hoadena Ingram v. Habeas Corpus

Present: The Honorable MARIA A. AUDERO, United States Magistrate Judge

James Muñoz N/A Deputy Clerk Court Reporter / Recorder

Attorneys Present for Plaintiff: Attorneys Present for Defendants: N/A N/A

Proceedings (In Chambers): Order re: Filing of Petition

On July 30, 2020, the Court received and filed Petitioner Hoadena Ingram’s pro se petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254. (“Petition,” ECF No. 1.) The Petition alleges one ground for federal habeas relief. Petitioner challenges a 2013 sentencing enhancement that was based on prior convictions obtained by guilty plea. (Id., at 2–3.) He relies on a 2019 state legislative enactment, California Assembly Bill No. 1618, which renders void as against public policy certain guilty plea agreements that include a waiver of the right to raise claims based on future changes in the law. (Id. at 3–5.)

The Petition suffers from certain procedural defects that must be resolved before Petitioner may proceed with this action. These defects are listed below. The Court ORDERS Petitioner to respond to the following issues by no later than October 13, 2020.

Second or Successive Petition

The Petition appears to be an unauthorized second or successive petition challenging this conviction. If so, then the Petition is subject to summary dismissal for lack of jurisdiction.

Rule 4 of the Rules Governing Section 2254 Cases in the United States District Courts requires summary dismissal of federal habeas petitions “[i]f it plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief in the district court.”

28 U.S.C. § 2244(b) limits habeas petitioners from asserting certain claims in a second or successive petition without leave from a United States Court of Appeals. As articulated by the United States Supreme Court: CIVIL MINUTES – GENERAL

Case No.: 5:20-cv-01527-JVS-MAA Date: August 11, 2020 Title: Hoadena Ingram v. Habeas Corpus The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) established a stringent set of procedures that a prisoner “in custody pursuant to the judgment of a State court,” 28 U.S.C. § 2254(a), must follow if he wishes to file a “second or successive” habeas corpus application challenging that custody, § 2244(b)(1). In pertinent part, before filing the application in the district court, a prisoner “shall move in the appropriate court of appeals for an order authorizing the district court to consider the application.” § 2244(b)(3)(A). A three-judge panel of the court of appeals may authorize the filing of the second or successive application only if it presents a claim not previously raised that satisfies one of the two grounds articulated in § 2244(b)(2). § 2244(b)(3)(C); Gonzalez v. Crosby, 545 U.S. 524, 529–530, 125 S. Ct. 2641, 162 L. Ed. 2d 480 (2005); see also Felker v. Turpin, 518 U.S. 651, 656–657, 664, 116 S. Ct. 2333, 135 L. Ed. 2d 827 (1996). Burton v. Stewart, 549 U.S. 147, 152–53 (2007). District courts lack jurisdiction to consider unauthorized successive petitions and must dismiss such petitions. Id. at 153; see also 28 U.S.C. § 2244(b)(2); Rishor v. Ferguson, 822 F.3d 482, 490 (9th Cir. 2016).

In 2013, Petitioner was convicted of failing to inform local law enforcement authorities of his change of residence, as a registered sex offender, in violation of California Penal Code section 290.1 (See Petition, at 2.) He was sentenced to twenty-five years to life in prison. (Id.) In 2015, Petitioner filed his first petition for writ of habeas corpus pursuant to 28 U.S.C. § 2254, raising several claims challenging his 2013 sentence. Pet., Ingram v. Arnold, No. 5:15-cv-02084-JVS-AJW (“Ingram I”) (C.D. Cal. Oct. 9, 2015), ECF No. 1. The District Court rejected Petitioner’s claims on the merits

1 The Court takes judicial notice of Petitioner’s prior federal habeas case relating to this conviction and sentence. See Fed. R. Evid. 201(b)(2) (“The court may judicially notice a fact that is not subject to reasonable dispute because it . . . can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned.”); Harris v. County of Orange, 682 F.3d 1126, 1131–32 (9th Cir. 2012) (court may take judicial notice of “documents on file in federal or state courts”); Smith v. Duncan, 297 F.3d 809, 815 (9th Cir. 2001) (taking judicial notice of “relevant state court documents” because they “have a direct relationship to” federal habeas proceedings), overruled on other grounds by Pace v. DiGuglielmo, 544 U.S. 408, 418 (2005). CIVIL MINUTES – GENERAL

Case No.: 5:20-cv-01527-JVS-MAA Date: August 11, 2020 Title: Hoadena Ingram v. Habeas Corpus and dismissed the petition with prejudice. Report & Recommendation (“R&R”), Ingram I (C.D. Cal. May 25, 2016), ECF No. 10; Order Accepting R&R, Ingram I (C.D. Cal. June 23, 2016), ECF No. 14; Judgment, Ingram I (C.D. Cal. June 23, 2016), ECF No. 15. The District Court denied a certificate of appealability. Order Denying Certificate of Appealability, Ingram I (C.D. Cal. June 23, 2016), ECF No. 13. Petitioner did not move for a certificate of appealability in the United States Court of Appeals for the Ninth Circuit.

The Petition appears to be an unauthorized second or successive petition. Petitioner’s prior petition for writ of habeas corpus, which was predicated on the same 2013 criminal judgment, was dismissed on the merits. Accordingly, a subsequent petition challenging the same judgment constitutes a “second or successive” habeas petition relative to the Ingram I petition. Because the instant Petition is predicated on the same conviction and sentence challenged in the Ingram I petition, the Petition appears to be second or successive relative to the Ingram I action.

Even if Petitioner could demonstrate that he qualifies for an exception to the bar on successive petitions, he must have obtained permission from the Ninth Circuit before bringing the claims in the instant Petition. Woods v. Carey, 525 F.3d 886, 888 (9th Cir. 2008). Petitioner has not shown that he sought or obtained authorization to file the instant Petition with any United States Court of Appeals. (See generally Petition.) The Court’s independent search of the Ninth Circuit Court of Appeals’ dockets using the electronic PACER case locator function indicates Petitioner neither sought nor obtained such authorization.

Accordingly, this district court appears to lack jurisdiction to entertain the Petition, and summary dismissal is appropriate.

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Related

Felker v. Turpin
518 U.S. 651 (Supreme Court, 1996)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Burton v. Stewart
549 U.S. 147 (Supreme Court, 2007)
Jerryal Culler v. Board of Prison Terms
405 F. App'x 263 (Ninth Circuit, 2010)
Timothy Young v. United States
465 F. App'x 597 (Ninth Circuit, 2012)
Jerry F. Stanley v. California Supreme Court
21 F.3d 359 (Ninth Circuit, 1994)
David C. Smith v. W.A. Duncan, Warden
297 F.3d 809 (Ninth Circuit, 2002)
Gonzalez v. Crosby
545 U.S. 524 (Supreme Court, 2005)
Harris v. County of Orange
682 F.3d 1126 (Ninth Circuit, 2012)
Woods v. Carey
525 F.3d 886 (Ninth Circuit, 2008)
Kirk Rishor v. Bob Ferguson
822 F.3d 482 (Ninth Circuit, 2016)
Ortiz-Sandoval v. Gomez
81 F.3d 891 (Ninth Circuit, 1996)

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Hoadena Ingram v. Habeas Corpus, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hoadena-ingram-v-habeas-corpus-cacd-2020.