Luis A. Arroyo v. George Jaime

CourtDistrict Court, C.D. California
DecidedNovember 24, 2020
Docket2:20-cv-06135
StatusUnknown

This text of Luis A. Arroyo v. George Jaime (Luis A. Arroyo v. George Jaime) 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
Luis A. Arroyo v. George Jaime, (C.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 LUIS A. ARROYO, ) NO. CV 20-6135-E ) 12 Petitioner, ) ) 13 v. ) MEMORANDUM OPINION AND ) 14 WARDEN GEORGE JAIME, ) ORDER DENYING PETITION FOR ) 15 Respondent. ) WRIT OF HABEAS CORPUS ______________________________) 16 17 18 PROCEEDINGS 19 20 Petitioner filed a “Petition for Writ of Habeas Corpus By a 21 Person in State Custody” on July 9, 2020. Respondent filed a “Motion 22 to Dismiss etc.” on October 30, 2020. Petitioner filed a Reply and a 23 Traverse on November 18, 2020. Petitioner and Respondent have 24 consented to proceed before a United States Magistrate Judge. 25 /// 26 /// 27 /// 28 /// 1 BACKGROUND 2 3 Pursuant to a guilty plea in Ventura County Superior Court, 4 Petitioner received a twelve year prison sentence on June 15, 2017 5 (Petition at 2). Petitioner’s appellate counsel filed a “Wende brief” 6 on direct appeal (id.; Lodged Document 1). The California Court of 7 Appeal dismissed Petitioner’s direct appeal on March 26, 2018 8 (Petition at 3; Lodged Document 1). Petitioner asserts that he did 9 not receive notice of this dismissal until May 22, 2018 (“Declaration 10 of Luis Avila Arroyo,” dated December 3, 2019 (attached to Petition)). 11 12 Petitioner did not file a petition for review (see Lodged 13 Document 1).1 Petitioner did not file any application for state 14 collateral review until December 9, 2019, when he reportedly filed a 15 habeas corpus petition in the Court of Appeal (Petition at 3-4). 16 Subsequently, Petitioner also filed a habeas corpus petition in the 17 California Supreme Court (Petition at 4; Lodged Document 2). 18 19 In the present federal Petition, Petitioner alleges three claims: 20 (1) the Court of Appeal should have remanded the matter under newly 21 enacted Senate Bill 620 to allow the sentencing court to exercise its 22 discretion to strike Petitioner’s ten year sentence enhancement; 23 (2) appellate counsel was ineffective for failing to request such a 24 25 26 1 The Court takes judicial notice of the docket of the California Supreme Court, available at www.courts.ca.gov. 27 See Porter v. Ollison, 620 F.3d 952, 954-55 n.1 (9th Cir. 2001). The docket reflects that Petitioner never filed a petition for 28 1 remand;2 and (3) appellate counsel’s representation of Petitioner was 2 so deficient as to violate Petitioner’s due process rights. 3 4 DISCUSSION 5 6 As discussed below, the applicable statute of limitations bars 7 the present Petition. 8 9 I. The Statute 10 11 The “Antiterrorism and Effective Death Penalty Act of 1996” 12 (“AEDPA”), signed into law April 24, 1996, amended 28 U.S.C. section 13 2244 to provide a one-year statute of limitations governing habeas 14 petitions filed by state prisoners: 15 16 (d)(1) A 1-year period of limitation shall apply to an 17 application for a writ of habeas corpus by a person in 18 custody pursuant to the judgment of a State court. The 19 limitation period shall run from the latest of – 20 21 (A) the date on which the judgment became final by the 22 conclusion of direct review or the expiration of the time 23 for seeking such review; 24 /// 25 26 2 During the direct appeal, Petitioner evidently had 27 urged his appellate counsel to raise the Senate Bill 620 issue with the Court of Appeal. See May 22, 2018 letter attached to 28 1 (B) the date on which the impediment to filing an 2 application created by State action in violation of the 3 Constitution or laws of the United States is removed, if the 4 applicant was prevented from filing by such State action; 5 6 (C) the date on which the constitutional right asserted was 7 initially recognized by the Supreme Court, if the right has 8 been newly recognized by the Supreme Court and made 9 retroactively applicable to cases on collateral review; or 10 11 (D) the date on which the factual predicate of the claim or 12 claims presented could have been discovered through the 13 exercise of due diligence. 14 15 (2) The time during which a properly filed application for 16 State post-conviction or other collateral review with 17 respect to the pertinent judgment or claim is pending shall 18 not be counted toward any period of limitation under this 19 subsection. 20 21 “AEDPA’s one-year statute of limitations in § 2244(d)(1) applies to 22 each claim in a habeas application on an individual basis.” Mardesich 23 v. Cate, 668 F.3d 1164, 1171 (9th Cir. 2012). 24 25 II. Accrual 26 27 The California Court of Appeal’s March 26, 2018 dismissal of 28 Petitioner’s direct appeal became “final in that court” on April 25, 1] 2018. See Cal. Ct. R. 8.366(b) (1) (Court of Appeal decision in 2| criminal case is “final in that court 30 days after filing”). However, 3] Petitioner’s conviction did not become “final” for purposes of the 4| federal statute of limitations until May 5, 2020. See Gonzalez v. 5| Thaler, 565 U.S. 134, 150 (2012) (if the petitioner did not pursue 6| discretionary review in the state’s highest court on direct appeal, the conviction becomes “final” for statute of limitations purposes 8| when the time for seeking such review expired); Smith v. Duncan, 297 9| F.3d 809, 813 (9th Cir. 2002), abrogation on other grounds recognized 10] in Moreno v. Harrison, 245 Fed. App’x 606 (9th Cir 2007), cert. 11] denied, 552 U.S. 1121 (2008) (if a California petitioner does not file a petition for review on direct appeal, the conviction becomes “final” for purposes of the statute of limitations when the time for filing a 14] petition for review expired); Cal. Ct. R. 8.500(e) (1) (“A petition for 15] review must be served and filed within 10 days after the Court of Appeal decision is final in that court”). Therefore, the statute of 17] limitations commenced running from May 5, 2018, unless subsections B, 18] C or D of section 2244(d) (1) provide a later accrual date. 19 20 Subsection B does not provide a later accrual date. To warrant 21| delayed accrual under subsection B, Petitioner must show that illegal 22| conduct by the state or those acting for the state “made it impossible 23|| for him to file a timely § 2254 petition in federal court.” See 24|| Ramirez v. Yates, 571 F.3d 993, 1000-01 (9th Cir. 2009). Petitioner 25|| must show a causal connection between the impediment and his failure to file a timely federal petition. See Bryant v. Arizona Atty. 27| General, 499 F.3d 1056, 1059-60 (9th Cir. 2007) (citations omitted). 28| Petitioner “must satisfy a far higher bar than that for equitable

tolling.” Ramirez v. Yates, 571 F.3d at 1000. Petitioner is entitled to delayed accrual under subsection B only if the alleged impediment 3] “altogether prevented him from presenting his claims in any form, to 4) any court.” Id. at 1001 (emphasis original; citation omitted). In the present case, no illegal state action prevented Petitioner from 6| filing the present Petition sooner. 7 8 Contrary to Petitioner’s apparent argument, the purported actions 9] or omissions of Petitioner’s appellate counsel are not attributable to the state under subsection B. See Lawrence v. Florida, 421 F.3d 1221, 11] 1226 (11th Cir. 2005), aff’d on other grounds, 549 U.S. 327 (2007) 12] (rejecting argument that the state created an impediment by providing 13) incompetent counsel; “[t]his is not the type of State impediment 14] envisioned in § 2244(d) (1) (B)”); Ibarra v. Ground, 2012 WL 3259898, at 15) *3 (C.D. Cal. July 9, 2012), adopted, 2012 WL 3257883 (C.D. Cal. 16] Aug.

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Bluebook (online)
Luis A. Arroyo v. George Jaime, Counsel Stack Legal Research, https://law.counselstack.com/opinion/luis-a-arroyo-v-george-jaime-cacd-2020.