Joseph Hetzel v. Brian Cates

CourtDistrict Court, C.D. California
DecidedApril 20, 2022
Docket2:22-cv-02516
StatusUnknown

This text of Joseph Hetzel v. Brian Cates (Joseph Hetzel v. Brian Cates) 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
Joseph Hetzel v. Brian Cates, (C.D. Cal. 2022).

Opinion

Case 2:22-cv-02516-CJC-MAR Document 4 Filed 04/20/22 Page 1 of 5 Page ID #:45 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES – GENERAL

Case No. 2:22-cv-2516-CJC(MAR) Date: April 20, 2022 Title: Joseph Hetzel v. Brian Cates Present: The Honorable: MARGO A. ROCCONI, UNITED STATES MAGISTRATE JUDGE ERICA BUSTOS N/A Deputy Clerk Court Reporter / Recorder

Attorneys Present for Petitioner: Attorneys Present for Defendants: N/A N/A Proceedings: (In Chambers) ORDER TO SHOW CAUSE: WHY PETITION SHOULD NOT BE SUMMARILY DISMISSED AS UNTIMELY

I. INTRODUCTION

Petitioner Joseph Hetzel (“Petitioner”), proceeding pro se, constructively filed1 a Petition for Writ of Habeas Corpus by a Person in State Custody (“Petition”) pursuant to 28 U.S.C. § 2254 (“section 2254”). ECF Docket No. (“Dkt.”) 1. The Petition appears untimely. However, the Court will not make a final determination regarding whether the Petition should be dismissed without giving Petitioner an opportunity to explain why the Petition is not untimely.

II. PROCEDURAL HISTORY

On February 21, 2019, Petitioner pled guilty to violations of Cal. Pen. Code §§ 207(a), 667(a)(1). Id. at 2. Because Petitioner entered into a plea bargain, he did not appeal the conviction. Id. at 3.

Petitioner indicates he filed a habeas petition in Santa Barbara County Superior Court on March 2, 2021. Id. A case search on the California Courts Appellate Courts Case Information website confirms that: (1) on July 8, 2021, Petitioner filed a petition for writ of habeas corpus in the Court of Appeal, which the court denied on Ju;y 27, 2021;2 and (2) on August 18, 2021, Petitioner filed a petition for writ of habeas corpus in the California Supreme Court, which the court denied on November 10, 2021.3 Dkt. 1 at 4–5.

1 Under the “mailbox rule,” when a pro se prisoner gives prison authorities a pleading to mail to court, the court deems the pleading constructively “filed” on the date it is signed. Roberts v. Marshall, 627 F.3d 768, 770 n.1 (9th Cir. 2010).

2 See California Courts, Appellate Courts Case Information, 2nd Appellate District, Docket (https://appellatecases.courtinfo.ca.gov/search/case/mainCaseScreen.cfm?dist=2&doc_id=2353169&doc_no=B31347 4&request_token=NiIwLSEmPkw7WyApSSFdUENIUEA6USxXIiIuVz1SMCAgCg%3D%3D) (last accessed on April 19, 2022).

3 See California Courts, Appellate Courts Case Information, Supreme Court, Docket (https://appellatecases.courtinfo.ca.gov/search/case/mainCaseScreen.cfm?dist=0&doc_id=2356210&doc_no=S2704

CV-90 (03/15) Civil Minutes – General Page 1 of 5 Case 2:22-cv-02516-CJC-MAR Document 4 Filed 04/20/22 Page 2 of 5 Page ID #:46 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Case No. 2:22-cv-2516-CJC(MAR) Date: April 20, 2022 Title: Joseph Hetzel v. Brian Cates

Petitioner constructively filed the instant Petition on April 9, 2022. Dkt. 1 at 8.

III. DISCUSSION

A. THE PETITION IS UNTIMELY AND SUBJECT TO DISMISSAL

1. The Petition was filed after AEDPA’s one-year limitations period

a. Applicable law

AEDPA “sets a one-year limitations period in which a state prisoner must file a federal habeas corpus petition.” Thompson v. Lea, 681 F.3d 1093, 1093 (9th Cir. 2012). Ordinarily, the limitations period runs from the date on which the prisoner’s judgment of conviction “became final by the conclusion of direct review or the expiration of the time for seeking such review.” 28 U.S.C. § 2244(d)(1).

b. Analysis

Here, Petitioner filed the Petition after April 24, 1996, the effective date of AEDPA. Dkt. 1. Therefore, the requirements for habeas relief set forth in AEDPA apply. Soto v. Ryan, 760 F.3d 947, 956–57 (9th Cir. 2014).

Here, it appears that Petitioner did not pursue direct review of his conviction. Therefore, Petitioner’s conviction became final on April 22, 2019, i.e., sixty (60) days after the time expired for Petitioner to appeal his conviction See Dkt. 1; see also Cal. R. Ct. 8.304, 8.308 (state court rules setting forth 60-day time period in which to initiate criminal appellate proceedings). AEDPA’s one- year limitations period commenced the next day, April 23, 2019, and expired on April 23, 2020. 28 U.S.C. § 2244(d)(1). However, Petitioner filed the Petition on April 9, 2022. Dkt. 1 at 8. Therefore, in the absence of a later trigger date or any applicable tolling, the Petition appears untimely under 28 U.S.C. § 2244(d)(1) (“section 2244(d)(1)”). Thompson, 681 F.3d at 1093. /// /// /// ///

40&request_token=NiIwLSEmPkw7WyApSSFdUEJJUEA0UDxTJCJeVz5TMCAgCg%3D%3D) (last accessed on April 19, 2022).

CV-90 (03/15) Civil Minutes – General Page 2 of 5 Case 2:22-cv-02516-CJC-MAR Document 4 Filed 04/20/22 Page 3 of 5 Page ID #:47 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Case No. 2:22-cv-2516-CJC(MAR) Date: April 20, 2022 Title: Joseph Hetzel v. Brian Cates 2. Petitioner is not entitled to a later trigger date

Pursuant to section 2244(d)(1), there are three (3) situations where a petitioner may be entitled to a later trigger date of the one-year limitation period beyond the date of his conviction becoming final. 28 U.S.C. § 2244(d)(1).

First, under Subsection (B), if a state action prevented a petitioner from filing a federal habeas claim in violation of the Constitution or laws of the United States, the limitations period begins to run on “the date on which the impediment to filing an application created by State action . . . is removed[.]” 28 U.S.C. § 2244(d)(1)(B).

Second, under Subsection (C), if a right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review, the limitations period begins to run on the “date on which the constitutional right asserted was initially recognized by the Supreme Court[.]” 28 U.S.C. § 2244(d)(1)(C).

Third, under Subsection (D), if a petitioner brings newly-discovered claims, the limitations period begins to run on “the date on which the factual predicate of the claim or claims presented could have been discovered through the exercise of due diligence.” 28 U.S.C. § 2244(d)(1)(D). However, “AEDPA’s one-year statute of limitations in § 2244(d)(1) applies to each claim in a habeas application on an individual basis.” Mardesich v. Cate, 668 F.3d 1164, 1171 (9th Cir. 2012). A different triggering date, therefore, may apply to each claim in a petition. Id.

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Joseph Hetzel v. Brian Cates, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-hetzel-v-brian-cates-cacd-2022.