John Richard Pokras v. Superior Court of Los Angeles

CourtDistrict Court, C.D. California
DecidedMay 20, 2021
Docket2:21-cv-03545
StatusUnknown

This text of John Richard Pokras v. Superior Court of Los Angeles (John Richard Pokras v. Superior Court of Los Angeles) 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
John Richard Pokras v. Superior Court of Los Angeles, (C.D. Cal. 2021).

Opinion

2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 JOHN RICHARD POKRAS, Case No. 2:21-cv-03545-JVS (GJS) 12 Petitioner ORDER: SUMMARILY 13 v. DISMISSING PETITION; AND DENYING A CERTIFICATE OF 14 SUPERIOR COURT OF LOS APPEALABILITY ANGELES, 15 Respondent. 16 17 18 On April 23, 2019, Petitioner filed a 28 U.S.C. § 2254 habeas petition in this 19 District Court [Dkt. 1,“Petition”]. The Petition stems from Petitioner’s state 20 criminal sentence and, possibly, from the COVID pandemic, as discussed below 21 [Petition at 3.]1 22 Rule 4 of the Rules Governing Section 2254 Cases in the United States 23 District Courts requires summary dismissal of Section 2254 petitions “[i]f it plainly 24 appears from the petition and any attached exhibits that the petitioner is not entitled 25 to relief in the district court.” Rule 4, 28 U.S.C. foll. § 2254. The Court has 26 carefully considered the Petition and related documents filed by Petitioner, as well 27 as the record, and finds that summary dismissal of this action, without prejudice, is 28 required. 2 BACKGROUND 3 In 2005, a jury in Los Angeles County Superior Court Case No. NA057095 4 found Petitioner guilty of second degree murder and found a personal and 5 intentional discharge of a firearm enhancement allegation (California Penal Code §§ 6 12022.53(b)-(d)) to be true. The trial court separately determined that Petitioner had 7 suffered a prior “strike” felony conviction. Petitioner was sentenced to a total of 60 8 years to life in state prison. 9 Petitioner appealed (Case No. B181538). On January 19, 2006, the California 10 Court of Appeal affirmed the judgment. Petitioner filed a petition for review in the 11 California Supreme Court (Case No. S141249). On March 29, 2006, the California 12 Supreme Court denied review without comment or citation to authority. 13 The California appellate dockets do not show any cases brought by Petitioner 14 other than the above two direct appeal proceedings. A review of the trial court’s 15 docket shows a last entry date in August 2019, and it does not show any habeas or 16 other collateral review filings by Petitioner related to the issues raised in the 17 Petition. 18 Petitioner apparently has pursued some administrative remedies, albeit 19 incompletely. The Petition attaches copies of documents related to a January 2021 20 initial level grievance filed by Petitioner, which was based on his contention that he 21 is eligible for a parole hearing and possible resentencing under Proposition 57 22 (discussed below). The grievance was denied on April 2, 2021, based on a finding 23 that Petitioner is ineligible for relief under Proposition 57, because his murder 24 conviction (30-year term) and the imposed Section 12022.53 enhancement 25 (consecutive 25-year term) both constitute violent felonies rendering him ineligible 26 for referral for nonviolent offender parole consideration. [See Petition at 10-20.] 27 Although the April 2, 2021 decision advised Petitioner that he could file an appeal 28 with the Office of Appeals of the California Department of Correction and 2 prior to the April 20, 2021 mailing date of the Petition.2 3 As discussed below, the Petition seeks relief based on both California 4 Proposition 57 and California Senate Bill 620. As to the latter, Senate Bill 620 5 became effective on January 1, 2018, and it amended California Penal Code §§ 6 12022.5(c) and 12022.53(h) to allow a trial court – at the time of sentencing or 7 resentencing and when in the interest of justice – to strike or dismiss a firearm 8 enhancement otherwise required to be imposed by these two statutes. In November 9 2016, California voters approved Proposition 57, which made parole more available 10 for certain felons convicted of nonviolent crimes. As implemented in the California 11 Constitution at Art. I, sec. 32(a)(1), Proposition 57 provides: “Parole consideration: 12 Any person convicted of a nonviolent felony offense and sentenced to state prison 13 shall be eligible for parole consideration after completing the full term of his or her 14 primary offense.” Proposition 57, thus, did not mandate that inmates convicted of 15 nonviolent crimes actually be paroled but, rather, that they be eligible for parole 16 consideration once they have completed the required base term. 17 18 PETITIONER’S HABEAS CLAIM(S) 19 The Petition alleges only a “Ground 1” claim. In the portion of the claim in 20 which a petitioner is required to briefly state the ground for relief, the Petition 21 contains what appears to be pre-printed boilerplate text asserting that unspecified 22 conditions of confinement violate the Eighth Amendment due to the COVID 23 pandemic, because such conditions place a “vulnerable” inmate at a high risk of 24 death or serious health complications. No facts are stated to support this generic 25 allegation and, instead, the preprinted text directs the Court to “see” “Exhibits” and 26 2 The Petitioner also attaches a March 25, 2021 CDCR grievance receipt acknowledgement 27 form, which indicates that Petitioner submitted a different initial level grievance on March 24, 28 2021, and that review was to be completed by May 24, 2021. (See Petition at 21.) The Petition does not contain any evidence regarding the substance of that grievance. 2 Petition. [Petition at 3.] 3 It is unclear whether Petitioner actually intends to proffer an Eighth 4 Amendment/COVID-based claim for habeas relief or, instead, has simply utilized a 5 preprinted form and added his real claim to it. Petitioner’s actual claim seems to be 6 that which is set forth in the Supporting Facts section of Ground 1. Petitioner asks 7 the Court “on its own motion” to exercise its judicial discretion to resentence him – 8 pursuant to Proposition 57 and Senate Bill 620 – by striking the firearm 9 enhancement (and its related lengthy consecutive sentence). He discusses the 10 history of these two state law provisions and asserts, without explanation, that the 11 “Legislature intended” Senate Bill 620 to apply retroactively. Petitioner cites to 12 numerous state court decisions, attaching a copy of one of them to the Petition along 13 with documents related to his sentence and parole eligibility. [Petition at 3-4 and 14 attached documents.] 15 16 DISCUSSION 17 The Court concludes that the Petition fails on its face, and therefore, its 18 summary dismissal is required pursuant to Rule 4. The Court reaches this 19 conclusion for the following reasons: 20 21 Procedural Defects 22 The Petition suffers from several procedural defects. First, under Rule 11(a) 23 of the Federal Rules of Civil Procedure, every pleading submitted for filing must be 24 signed by the party personally if not represented. Further, under Rule 2(c)(5) of the 25 Rules Governing Section 2254 Cases in the United States District Court (“Habeas 26 Rules”), Petitioner was required to sign the Petition under penalty of perjury. The 27 Petition, however, is unsigned, in violation of both Rule 11(a) and Rule 2(c)(5). 28 Accordingly, under Rule 11(a), the Court “must strike” the Petition unless the defect 2 Second, under Rule 2(a) of the Habeas Rules, when a habeas petitioner is in 3 state custody, “the petition must name as respondent the state officer who has 4 custody” of the petitioner. See also Stanley v. California Supreme Court, 21 F.3d 5 359, 360 (9th Cir. 1994). Failure to name a petitioner’s actual custodian deprives 6 federal courts of personal jurisdiction over the custodian, and thus, over anyone who 7 can provide habeas relief if granted. See id.. The sole named Respondent is the Los 8 Angeles County Superior Court, an entity that does not have custody of Petitioner. 9 The Petition, thus, violates Rule 2(a) of the Habeas Rules.

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Bluebook (online)
John Richard Pokras v. Superior Court of Los Angeles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-richard-pokras-v-superior-court-of-los-angeles-cacd-2021.