Jerome Eugene Kelly v. E. Mejia

District Court, C.D. California·Decided February 25, 2026·No. 2:25-cv-00192·Unknown

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JEROME EUGENE KELLLY, Case No. 8:25-cv-02843-FWS-PD Petitioner, ORDER (1) TO SHOW CAUSE WHY PETITION SHOULD v. NOT BE DISMISSED AND (2) TO FILE COMPLETED E. MEJIA, DECLARATION IN SUPPORT Respondent. OF REQUEST TO PROCEED IN FORMA PAUPERIS OR

On December 9, 2025, Petitioner Jerome Eugene Kelly, proceeding pro se, constructively filed a Petition for Writ of Habeas Corpus by a Person in State Custody pursuant to 28 U.S.C. § 2254, asserting two grounds for relief. 1

1 Under the mailbox rule of Houston v. Lack, 487 U.S. 266, 275-76 (1988), a prisoner constructively files something on the day he gives it to prison authorities for forwarding to the relevant court. See Roberts v. Marshall, 627 F.3d 768, 770 n.1 (9th Cir. 2010). Courts presume that is the day the prisoner signs the document unless there is evidence to the contrary. See Butler v. Long, 752 F.3d 1177, 1178 n.1 (9th Cir. 2014) (per curiam) (as amended). Here, Petitioner apparently signed the Petition on December 9, 2025. The Court therefore uses that date as the Petition’s The Court orders Petitioner to show cause why the Petition should not be dismissed because, on its face, it suggests that both claims are untimely and that one of the claims is both not cognizable on federal habeas review and unexhausted. The Court also orders Petitioner to either file a completed declaration in support of his request to proceed in forma pauperis or pay the appropriate filing fee. I. Procedural History and Petitioner’s Contentions A. Trial and Direct Appeal In July 2011, an Orange County Superior Court jury found Petitioner guilty of kidnapping, kidnapping to commit a sex offense, forcible oral copulation, and two counts of forcible sodomy. See Kelly v. Lizarraga, No. 8:15-cv-00263-GW-PJW, Dkt. No. 20 at 1 (C.D. Cal. filed on Feb. 13, 2015).2 After he was found to have been previously convicted of a strike under California’s Three Strikes law, he was sentenced to 120 years to life in prison. See id. at 2. Petitioner appealed, and on September 13, 2013, the California Court of Appeal modified his sentence but otherwise affirmed. See id., Dkt. No. 16-13. He sought review in the California Supreme Court, which denied review on November 26, 2013. See Cal. App. Cts. Case Info., available at http:// appellatecases.courtinfo.ca.gov/ (search case no. S214165) (last visited Feb. 24, 2026).

LaMarque, 319 F.3d 1199, 1201 (9th Cir. 2003) (mailbox rule applies to state habeas petitions).

2 As related below, Petitioner has previously filed a federal habeas petition challenging his 2011 state-court convictions. The Court takes judicial notice of that petition as well as the relevant filings and lodgments in connection with that case. See Harris v. County of Orange, 682 F. 3d 1126, 1131-32 (9th Cir. 2012); Fed. R. Evid. B. Prior Federal Habeas Petition This is not the first federal habeas petition that Petitioner has filed challenging his 2011 state-court convictions and sentence. On February 13, 2015, he filed his first one, which was denied with prejudice on its merits on January 17, 2017. See Kelly, Dkt. Nos. 20, 23-24. C. Subsequent State-Court Proceedings One of the Petition’s grounds for relief concerns Petitioner’s sentence. More than six years after the original sentencing, the Correctional Case Records Manager sent a letter to the trial court indicating that Petitioner’s abstract of judgment was incorrect. See Dkt. No. 1 at 29. On March 3, 2021, the trial court “corrected” Petitioner’s sentence by ordering that he be sentenced to 100 years to life plus five years. However, no resulting abstract of judgment was ever issued.3 See id. at 30. The Petition’s other ground for relief concerns the California Racial Justice Act (“CRJA”), which became effective on January 1, 2021. See Rose v. Warden, No. 2:22-cv-08155-DOC(LAL), 2023 WL 9601243, at *9 (C.D. Cal. Dec. 23. 2023). The CRJA prohibits the state from “seek[ing] or obtain[ing] a criminal conviction or seek[ing], obtain[ing], or impos[ing] a sentence on the basis of race, ethnicity, or national origin.” Cal. Penal Code § 745(a). Although it initially applied only to convictions that were not yet final before its effective date, it was amended on January 1, 2023, to provide that, beginning on January 1, 2024, petitioners may challenge sentences regardless of when their judgments became final. See Cal. Penal Code § 745(j)(3); see also Assemb. Bill 256, 2022 Cal. Legis. Serv. Ch. 739 § 2.

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