In re Salinas CA4/1

CourtCalifornia Court of Appeal
DecidedJanuary 12, 2015
DocketD065052
StatusUnpublished

This text of In re Salinas CA4/1 (In re Salinas CA4/1) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Salinas CA4/1, (Cal. Ct. App. 2015).

Opinion

Filed 1/12/15 In re Salinas CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

In re LUIS ANGEL SALINAS D065052

on (Imperial County Super. Ct. No. EHC01780) Habeas Corpus.

Petition for Writ of Habeas Corpus. Relief granted.

Janice R. Mazur, under appointment by the Court of Appeal, for Petitioner.

Kamala D. Harris, Attorney General, Jennifer A. Neill, Assistant Attorney

General, Phillip J. Lindsay and Gregory J. Marcot, Deputy Attorneys General, for

Plaintiff and Respondent.

Petitioner Luis Salinas is serving a prison sentence of 25 years to life. In 2012,

Salinas was notified he was being investigated as a prison gang associate and was placed

in the institution's security housing unit (SHU) pending completion of the investigation.

The investigation ultimately validated Salinas as an associate of the Mexican Mafia

(EME) prison gang. Salinas remained in the SHU for approximately 10 months, during which time he was statutorily precluded from earning postconviction custody credits

because of his placement in the SHU. (Pen. Code, § 2933.6, subd. (a).)

Salinas petitioned this court for a writ of habeas corpus alleging the gang-

validation procedures employed by California's prison system violated his due process

rights under Wolff v. McDonnell (1974) 418 U.S. 539 (Wolff) insofar as the regulatory

scheme imposed a blanket ban on his right to call and confront witnesses. He

alternatively argues that, even if the decision validating him as a gang member is not

reversible per se based on denial of his due process rights under Wolff, the decision

validating him as a gang member should be reversed because the evidence did not satisfy

the required showing for validating him as a gang member. We conclude the gang

validation process, as applied to Salinas here, resulting in the loss of custody credits,

denied Salinas the due process right to seek to call witnesses as mandated by Wolff.1

FACTUAL AND PROCEDURAL BACKGROUND

The pertinent facts are largely undisputed. In October 2012 Salinas was notified

that an investigation had been completed into his alleged status as an "associate" with a

1 Our conclusions here are limited to the scheme for gang validation in effect and applied to Salinas. We note, however, that it appears California has drastically overhauled the validation process by the adoption of extensive amendments that became effective October 17, 2014. (See http://www.cdcr.ca.gov/Regulations/Adult_Operations/ docs/NCDR/2014NCR/14-02/Final_Text_of_Adopted_Regulations_STG.pdf.) Accordingly, our opinion will refer to the applicable provision of title 15 of the California Code of Regulations, as was operative and applicable to Salinas's validation, as the "former section" when the new regulatory scheme appears to have replaced the former regulatory section in effect at the time of Salinas's validation. All further statutory references are to title 15 of the California Code of Regulations unless otherwise noted.

2 prison gang,2 the EME, and stated there was sufficient evidence to validate that

determination. The October 2012 notice identified and disclosed four "source" items

upon which the validation relied, including (1) a piece of paper found in Salinas's cell

containing a Matlactomei symbol, which is a symbol "used by Mexican Mafia

associates"; (2) a confidential memo reporting staff found a note (also known as a "kite")

recovered in the administrative segregation unit identifying Salinas as "having the ability

to refer other inmates in their effort to communicate with associates or members"; (3) a

confidential memo stating staff found a note allegedly authored by Salinas under his gang

moniker (Red) referring to another validated gang member (Goofy) and concerning the

rules of conduct for gang members; and (4) a piece of paper found in Salinas's cell

containing the name, California Department of Corrections and Rehabilitation (CDCR)

number, and address of a validated EME associate, Raymond Tarin (also known by the

moniker "Goofy"), which gave Salinas "the ability to communicate and conduct illegal

gang activities on behalf of EME."

At the same time Salinas received the October 2012 notice, he was relocated into

the SHU pending completion of the investigation of his gang status. Salinas met with

investigators and provided oral and written responses to each of the four validation

sources, stated there was more than one prisoner with the moniker "Red," and denied

being involved with gangs. The investigators concluded Salinas's claims had no merit

2 A gang "associate" was described in the former administrative regulations as "an inmate/parolee or any person who is involved periodically or regularly with members or associates of a gang." (Former § 3378, subd. (c)(4).) 3 and forwarded the validation packet to the office of correctional safety (OCS) for review.

Officials reviewed the validation and in March 2013 found, pursuant to the validation

requirements of former section 3378, that all of the four source items met the validation

requirements, and therefore validated Salinas as an associate of the EME prison gang.

Salinas pursued and exhausted his administrative remedies, and his petition for

writ of habeas corpus in the superior court was denied. Shortly before his petition for

writ of habeas corpus in the superior court was denied, he was removed from the SHU

and placed in the general population under a two-year pilot project.

Salinas petitioned this court for a writ of habeas corpus and, after considering the

Attorney General's informal response, we issued an order to show cause why the relief

requested should not be granted, and appointed counsel for the petitioner. The Attorney

General filed a return, and Salinas filed a traverse to the return.

THE COMPETING CLAIMS

Salinas contends the procedures for gang validation must comply with the due

process protections required by Wolff because the consequences attending validation

include the loss of the inmate's ability to earn "custody credits," and he contends the

procedures applied to him did not comply with Wolff because an inmate was prohibited

from calling witnesses when contesting the prison authority's determination.3 The

3 Salinas also contends that, even assuming he was not denied his due process rights under Wolff, the four source items on which the validation relied in this case were insufficient under the guidelines for gang validation. The People counter that we should decline to provide for judicial review of the evidentiary basis for gang validation decisions but, if such review is warranted, we should apply the extremely deferential 4 People contend the due process protections required by Wolff concerning witnesses do

not apply to gang validation proceedings but, even if Wolff's protections might apply,

Salinas lacks standing to raise the instant due process challenge because he ceased losing

custody credits when he was removed from the SHU and placed in the general

population.

RELEVANT LAW

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

Related

Wolff v. McDonnell
418 U.S. 539 (Supreme Court, 1974)
Bryan R. Ramer v. Dareld Kerby
936 F.2d 1102 (Tenth Circuit, 1991)
Onofre T. Serrano v. S.W. Francis
345 F.3d 1071 (Ninth Circuit, 2003)
Wilkinson v. Austin
545 U.S. 209 (Supreme Court, 2005)
In re Cabrera
287 P.3d 72 (California Supreme Court, 2012)
In Re Rothwell
164 Cal. App. 4th 160 (California Court of Appeal, 2008)
In Re Johnson
176 Cal. App. 4th 290 (California Court of Appeal, 2009)
In Re Jenkins
240 P.3d 260 (California Supreme Court, 2010)
In re Sanchez
209 Cal. App. 4th 962 (California Court of Appeal, 2012)
In re Fernandez
212 Cal. App. 4th 1199 (California Court of Appeal, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
In re Salinas CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-salinas-ca41-calctapp-2015.