Kenneth Graham v. L.J. Milusnic

CourtDistrict Court, C.D. California
DecidedNovember 20, 2019
Docket2:19-cv-09806
StatusUnknown

This text of Kenneth Graham v. L.J. Milusnic (Kenneth Graham v. L.J. Milusnic) 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
Kenneth Graham v. L.J. Milusnic, (C.D. Cal. 2019).

Opinion

1 2

8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 KENNETH GRAHAM, Case No. CV 19-9806-DOC (GJS) 12 Petitioner ORDER DISMISSING PETITION 13 v. WITHOUT PREJUDICE

14 L.J. MILUSNIC, 15 Respondent. 16

17 18 Kenneth Graham (“Graham”) is a federal prisoner incarcerated within this 19 district. He filed a putative 28 U.S.C. § 2241 petition on November 15, 2019 20 (“Petition”) that raises four claims. Ground One challenges the validity of the 21 indictment, arguing that while Graham was convicted as an aider and abettor, the 22 indictment “did not have a principle [sic]” and, further, that the jury was not 23 instructed on aiding and abetting bases for criminal liability. Ground Two alleges 24 that Petitioner’s trial counsel provided ineffective assistance by failing to call alibi 25 witnesses, cross-examine “known drug addicts,” share witness statements with 26 Petitioner, negotiate a plea bargain, check on a DNA warrant that had not been 27 signed by a judge, argue “duel [sic] prosecution,” and make any motions on 28 Petitioner’s behalf. Ground Three asserts that an enhancement imposed pursuant to 1 18 U.S.C. § 924(e) is invalid, because Petitioner did not have three prior violent or 2 serious drug convictions. Finally, Ground Four asserts that Petitioner’s conviction 3 pursuant to 18 U.S.C. § 924(c) is invalid, because there was no violent predicate 4 offense. (Petition at 3-4.) 5 Habeas petitions brought pursuant to Section 2241 may be subjected to the 6 same screening requirements that apply to habeas petitions brought pursuant to 28 7 U.S.C. § 2254. See Rules 1(b) of the Rules Governing Section 2254 Cases in the 8 United States District Courts, 28 U.S.C. foll. § 2254 (which permits this Court to 9 “apply any or all of these rules” to any habeas petition), and Rule 4 of the same 10 (which mandates that a district court dismiss a petition without ordering a 11 responsive pleading where “it plainly appears from the petition and any attached 12 exhibits that the petitioner is not entitled to relief”); see also Bostic v. Carlson, 884 13 F.2d 1267, 1269-70 (9th Cir. 1989) (affirming district court’s dismissal of a Section 14 2241 petition under Habeas Rules 1(b) and 4); Local Rule 72-3.2 (authorizing 15 magistrate judge to prepare for district judge proposed order for summary dismissal 16 and proposed judgment if it plainly appears from the face of the habeas petition that 17 the petitioner is not entitled to relief). The Court has screened the Petition and, for 18 the following reasons, concludes that the Petition must be dismissed summarily. 19 20 BACKGROUND 21 Pursuant to Rule 201 of the Federal Rules of Civil Procedure, the Court takes 22 judicial notice of the federal dockets and filings available through the PACER 23 system. These records show that, in a 2015 federal jury trial in Case No. 1:13-cr- 24 00620-ELH, Graham was convicted in the United States District Court for the 25 District of Maryland (the “Sentencing Court”) of violating 18 U.S.C. §§ 1951(a), 26 924(c), and 922(g) (the “Conviction”). He thereafter received a sentence totalling 27 382 months. Graham appealed, and the United States Court of Appeals for the 28 Fourth Circuit affirmed the Conviction on April 4, 2016 (Case No. 15-4318). 1 On February 16, 2018, Graham filed a 28 U.S.C. § 2255 motion in the 2 Sentencing Court, which he thereafter supplemented through two filings 3 (collectively, the “Section 2255 Motion”). The Section 2255 Motion raised versions 4 of the same claims alleged in the instant Petition as Grounds Two through Four. On 5 October 16, 2018, the Sentencing Court found that the Section 225 Motion was 6 untimely under the 28 U.S.C. § 2255(f) statute of limitations and denied relief. 7 On April 25, 2019, Graham filed a motion in the Fourth Circuit seeking leave 8 to file a second or successive Section 2255 motion again challenging his conviction 9 under 18 U.S.C. § 924(c) (Case No. 19-207). On August 20, 2019, the Fourth 10 Circuit denied Graham leave to file a second or successive Section 2255 motion. 11 12 DISCUSSION 13 Federal courts have an independent obligation to examine their own 14 jurisdiction and may not entertain an action in which jurisdiction is lacking. 15 Hernandez v. Campbell, 204 F.3d 861, 865 (9th Cir. 2000). For federal prisoners 16 wishing to challenge matters related to their convictions and/or sentences, there are 17 two statutory bases for federal court jurisdiction, 28 U.S.C. § 2241 (“Section 2241”) 18 and 28 U.S.C. § 2255 (“Section 2255”). 19 A Section 2241 habeas petition may be filed by a federal prisoner to attack 20 the “execution of his sentence,” but not to attack its validity. White v. Lambert, 370 21 F.3d 1002, 1009 (9th Cir. 2004); Hernandez, 204 F.3d at 864. A motion under 22 Section 2255 generally is the exclusive post-appeal mechanism by which a federal 23 prisoner may challenge the legality of his conviction or sentence. See Muth v. 24 Fondren, 676 F.3d 815, 818 (9th Cir. 2012); Harrison v. Ollison, 519 F.3d 952, 955 25 (9th Cir. 2008). The instant Petition does not attack the execution of Graham’s 26 sentence; instead, the four claims raised in the Petition directly attack the validity of 27 Graham’s Conviction and related sentence. Thus, Graham’s present claims are 28 required to be raised by way of Section 2255 motion rather than Section 2241 1 habeas petition. 2 There is, however, “one exception” to the generally exclusive nature of the 3 Section 2255 remedy for federal prisoners who wish to challenge the validity of 4 their convictions and/or sentences. Stephens v. Herrera, 464 F.3d 895, 897 (9th Cir. 5 2006). Section 2255(e) contains a “savings clause” or “escape hatch,” which allows 6 a federal prisoner to seek Section 2241 relief when a Section 2255 motion is 7 “inadequate or ineffective to test the legality of his detention.” See id.; see also 8 Muth, 676 F.3d at 818; Harrison, 519 F.3d at 956. A finding that Section 2255 is an 9 inadequate or ineffective remedy constitutes “a narrow exception” to the rule that 10 Section 2255 provides a federal prisoner’s exclusive remedy for challenging a 11 conviction and/or sentence. United States v. Pirro, 104 F.3d 297, 299 (9th Cir.

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Kenneth Graham v. L.J. Milusnic, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kenneth-graham-v-lj-milusnic-cacd-2019.