Mark Anthony Gonzalez v. Nathanajah Breitenbach, et al.

District Court, D. Nevada·Decided August 17, 2026·No. 2:25-cv-01080·Unknown

Opinion

MARK ANTHONY GONZALEZ, Case No. 2:25-cv-01080-APG-BNW

Petitioner, ORDER GRANTING IN PART AND DENYING IN PART MOTION TO v. DISMISS

NATHANJAH BREITENBACH, et al., [ECF No. 10]

Respondents.

I. Summary In this habeas action, the respondents move to dismiss Mark Anthony Gonzalez’s petition for a writ of habeas corpus under 28 U.S.C. § 2254 on the grounds that his challenges to the validity of his guilty plea are not cognizable and are wholly unexhausted. ECF No. 10. For the reasons explained below, I grant the motion to dismiss Ground A(1) as procedurally defaulted and Ground A(2) as not cognizable, and deny the motion to dismiss Ground B. II. Background A. Guilty Plea and Sentence In February of 2024, Gonzalez pleaded guilty, under the terms of a guilty plea agreement, to two counts of residential burglary in Douglas County, Nevada, and he was sentenced to an aggregate of 96 to 240 months of imprisonment. ECF Nos. 7-29; 7-38 at 63; 7-39; 7-40. B. State Direct Appeal Gonzalez filed a counseled state direct appeal. ECF No. 7-49. In his opening brief, he argued his pleas were not knowing, voluntary, and intelligent, in violation of the federal constitution, because (1) there is an unresolved material conflict regarding his right to appeal as set forth in his plea canvass and guilty plea agreement; and (2) he was not admonished that the minimum sentence can be no more than 40% of the maximum sentence under NRS § 193.130(1). ECF Nos. 7-49 at 6–20; 7-51 at 6–20. The State argued that, according to Bryant v. State,1 issues regarding the validity of the plea were improperly raised on direct appeal and must be raised in a petition for a writ of habeas corpus. ECF No. 8-7 at 11–12. Gonzalez replied that his

challenge to the validity of the plea was properly raised on direct appeal under the exception to the rule in Bryant, set forth in Smith v. State,2 which he argued allows challenges to the validity of a guilty plea on direct appeal where the invalidity of the plea is apparent from the record. ECF No. 8-10 at 6. The Nevada Court of Appeals declined to consider the claims that the pleas are invalid because, citing Bryant and Smith, the claimed errors were not apparent from the record and Gonzalez did not raise them in the state district court in the first instance. ECF No. 8-14. Gonzalez immediately filed a timely petition for rehearing under Nev. R. App. P. 40, contending the Nevada Court of Appeals overlooked that his claims of error clearly appeared in the record. ECF No. 8-15 at 4–6. A month later, and before the Court of Appeals ruled on the petition for rehearing,

Gonzalez filed a motion to supplement his petition for rehearing to add a claim that the Nevada Court of Appeals overlooked that the rule in Bryant abrogated Gonzalez’s right to a state direct appeal in violation of Nev. Const. art. III, § 1(1), Nev. Const. art. VI, § 4, and NRS § 2.120(1). 1 See State v. Bryant, 102 Nev. 268, 272 (1986) (holding defendant may not challenge the validity of a guilty plea on direct appeal and must do so in the district court in the first instance, either by bringing a motion to withdraw the guilty plea, or by initiating a postconviction proceeding); but see Harris v. State, 130 Nev. 435, 437, 448 (2014) (holding statutory post- conviction habeas petition takes the place of a motion to withdraw a guilty plea and is the exclusive remedy for challenging the validity of a guilty plea made after sentencing). 2 See Smith v. State, 110 Nev. 1009, 1010 n.1 (1994) (noting “[a]lthough we stated in Bryant, 102 Nev. 268, that this court will not consider a challenge to the validity of a guilty plea unless the defendant first brings his or her challenge in the district court, this rule cannot be applied without exception. In cases such as this one where the error clearly appears from the record, it is a waste of judicial resources to require the defendant to start the process of review anew . . ..”). ECF No. 8-19 at 4. The record reflects that in a proposed supplement to the petition for rehearing, which was later stricken by the Nevada Court of Appeals,3 Gonzalez sought to assert that the rule in Bryant violates the United States Constitution. ECF No. 8-21 at 4. The Nevada Court of Appeals acknowledged it had discretion to suspend its own rules, but denied the motion

to supplement the petition for rehearing as untimely under Nev. R. App. P. 40(c), struck the supplement, and denied rehearing under Nev. R. App. P. 40(a) and 40(h). ECF No. 8-23 at 2 n.1. Gonzalez subsequently filed a petition for review with the Supreme Court of Nevada, arguing the Nevada Court of Appeals erroneously concluded Gonzalez’s guilty pleas were not constitutionally infirm, his constitutional claims of error are clear from the record, the application of Bryant violates the Nevada Constitution and Nevada law, the rule in Bryant violates the Fourteenth Amendment Due Process Clause, and Bryant should be revised and overruled. ECF No. 8-25 at 3. The Supreme Court of Nevada denied review under Nev. R. App. P. 40B(a) and (g). ECF No. 8-27. III. Grounds A and B of the Petition

Ground A of Gonzalez’s petition alleges (1) the rule in Bryant abrogates the constitutional right to file a direct appeal challenging the legal sufficiency of guilty pleas, in violation of a Fourteenth Amendment Due Process “liberty” interest; and (2) the rule in Bryant abrogates the constitutional right to file a direct appeal challenging the legal sufficiency of guilty pleas, and unconstitutionally divests the courts of their original appellate jurisdiction in violation of the state’s separation of powers doctrine. ECF No. 1 at 3–14. Ground B alleges the Nevada Court of Appeals’s factual finding that the claims of error do not “clearly appear in the record”

3 The parties did not provide a copy of the supplement that Gonzalez submitted with his state motion to supplement the petition for rehearing. (which would allegedly satisfy an exception to Bryant) was unreasonable considering the evidence presented in the State court proceedings, in violation of 28 U.S.C. § 2254. Id. IV. Discussion A. Ground A

1. Ground A is partially cognizable. The respondents move to dismiss Ground A of the petition as not cognizable because there is no federal constitutional right to appeal and Ground A challenges only the state appellate court’s misapplication of state law. ECF No. 10 at 8–11. Gonzalez acknowledges he has no federal constitutional right to appeal, and argues his claims are not that the state appellate courts misapplied state law. Rather, he claims that, because state law grants him constitutional and state statutory rights to a direct appeal, those rights are protected by the Fourteenth Amendment Due Process Clause. ECF No. 11 at 10–13. A state prisoner is entitled to federal habeas relief “only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.” See 28 U.S.C. § 2254(a);

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Mark Anthony Gonzalez v. Nathanajah Breitenbach, et al., (D. Nev. 2026).

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