Ollivier v. Devos

CourtDistrict Court, W.D. Washington
DecidedSeptember 4, 2024
Docket2:24-cv-01092
StatusUnknown

This text of Ollivier v. Devos (Ollivier v. Devos) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ollivier v. Devos, (W.D. Wash. 2024).

Opinion

1 2 3 4

5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 BRANDON OLLIVIER, CASE NO. 2:24-cv-01092-TMC-GJL 11 Petitioner, v. REPORT AND RECOMMENDATION 12 KEITH DEVOS, Noting Date: September 19, 2024 13 Respondent. 14

15 The District Court has referred this action to United States Magistrate Judge Grady J. 16 Leupold. Petitioner Brandon Ollivier, proceeding pro se, initiated this action by filing a federal 17 habeas Petition pursuant to 28 U.S.C. § 2254. Dkt. 1. After screening the Petition, the Court 18 ordered Petitioner to show cause why this action should not be dismissed for failure to state a 19 viable claim for habeas relief. Dkt. 4. Petitioner’s Response to the Show Cause Order was 20 received on August 29, 2024. Dkt. 5. 21 Upon review of Petitioner’s Response, the undersigned finds he has failed to show cause 22 and recommends this action be DISMISSED without prejudice in accordance with Rule 4 of 23 the Rules Governing § 2254 cases (“Habeas Rules”). 24 1 I. BACKGROUND 2 Petitioner is currently confined at the Special Commitment Center (“SCC”)—a facility 3 owned and operated by the Washington State Department of Social and Health Services 4 (“DSHS”) that provides mental health treatment for civilly committed sexually violent predators,

5 many of whom have already completed their term of incarceration as adjudged by a criminal 6 court. Dkt. 1; see also WASHINGTON STATE DEPARTMENT OF SOCIAL AND HEALTH SERVICES, 7 Special Commitment Center: What We Do, Behavioral Health Administration, 8 https://www.dshs.wa.gov/bha/special-commitment-center (accessed August 8, 2024). 9 As his sole ground for habeas relief, Petitioner alleges that he has been denied “statutorily 10 mandated adequate care” and “individualized treatment” for years while confined at SCC. Dkt. 1 11 at 3, 5. Petitioner asserts that these conditions make his detention unlawful and violate his due 12 process rights. Id. The relief requested in the Petition is Petitioner’s immediate release from 13 confinement and an award of monetary damages related to his confinement. Id. at 15. 14 As the Petition appeared to challenge the conditions of Petitioner’s confinement and

15 included a request for monetary damages, Petitioner was advised of the following and ordered to 16 show cause why this action should not be dismissed: 17 Upon review, it is clear on the face of the Petition that Petitioner is not entitled to habeas relief. Petitioner’s sole ground for relief is not a true habeas claim, but rather 18 a challenge to the conditions of his state confinement that must be brought in a civil rights action under 42 U.S.C. § 1983. Petitioner’s core allegations are that he is being 19 denied medical care and individualized therapy at SCC. Dkt. 1 at 3, 5. These allegations go to the conditions of his confinement at SCC, not the validity of his 20 civil custody decision or state court conviction. Although Petitioner seeks release from confinement in addition to monetary damages, this is the only aspect of his 21 claim that resembles a habeas action. Id. at 15. Nevertheless, Petitioner’s request for release does not convert his conditions of confinement claim to one sounding in 22 habeas. 23 Dkt. 4 at 3. Petitioner filed a timely Response to the Show Cause Order, which is now ripe for 24 consideration. Dkt. 5. 1 II. LEGAL STANDARD 2 Under Rule 4 of the Habeas Rules, the Court is required to perform a preliminary review 3 of a habeas petition. Rule 4 specifically directs the Court to dismiss a habeas petition before the 4 respondent is ordered to file a response, if it “plainly appears from the petition and any attached

5 exhibits that the petitioner is not entitled to relief in the district court.” 6 Under Rule 2(a) of the Habeas Rules, “the petition must name as respondent the state 7 officer who has custody.” Further, the petition must: 8 (1) specify all the grounds for relief available to the petitioner; (2) state the facts supporting each ground; (3) state the relief requested; (4) be printed, typewritten, or 9 legibly handwritten; and (5) be signed under penalty of perjury by the petitioner or person authorized to sign it for the petitioner under 28 U.S.C. § 2242. 10 11 Id. at Rule 2(c). The petition must “substantially follow” a form prescribed by the local district 12 court or the form attached to the Habeas Rules. Id. at Rule 2(d). 13 An “action lying at the core of habeas corpus is one that goes directly to the 14 constitutionality of the prisoner’s physical confinement itself.” Preiser v. Rodriguez, 411 U.S. 475, 15 503 (1973). Thus, “when a state prisoner is challenging the very fact or duration of his physical 16 imprisonment, and the relief he seeks is a determination that he is entitled to immediate release or a 17 speedier release from that imprisonment, his sole federal remedy is a writ of habeas corpus.” 18 Preiser, 411 U.S. at 500 (emphasis added). In contrast, an action challenging the conditions of state 19 confinement or seeking financial compensation for the same is not a true habeas action. Id. at 494 20 (“If a state prisoner is seeking damages, he is attacking something other than the fact or length of 21 his confinement and he is seeking something other than immediate or more speedy release.”). In 22 those instances, a prisoner must instead file a civil rights action pursuant to 42 U.S.C. § 1983. Heck 23 v. Humphrey, 512 U.S. 477, 482–83 (1994). These principles apply with equal force to individuals 24 1 who are civilly confined at state facilities consequent to state court convictions. See generally 2 Brock v. Weston, 31 F.3d 887, 888 (9th Cir. 1994). 3 III. DISCUSSION 4 In his Response, Petitioner offers to withdraw “any claim for damages [that] interferes or

5 confuses the issue” in this case. Dkt. 5 at 1. Petitioner also maintains that this suit is not one 6 concerning the conditions of his confinement, but rather an action going to the heart of habeas 7 corpus. Id. at 1–7. This Court disagrees. 8 Despite his offer to withdraw his request for damages and his assertions that this action 9 challenges “the very roots and purposes” of his confinement, Petitioner’s claim does not sound in 10 habeas. Moreover, Petitioner’s attempts to differentiate his claim from other conditions of 11 confinement claims by stating that he does not “attack the adequacy and quality of care” or the 12 competency of healthcare professionals at SCC are unavailing. Dkt. 5 at 4. The Court reaches 13 this conclusion because even a favorable disposition of Petitioner’s claim would not require his 14 release from confinement; instead, his alleged injuries are redressable by a court order directing

15 SCC to provide the sort of treatment required by law. See, e.g., Sharp v. Weston, 233 F.3d 1166 16 (9th Cir. 2000) (reviewing injunctive relief granted in § 1983 action to redress, among other 17 things, provision of inadequate individualized treatment program at SCC). 18 Notably, claims similar to those alleged in the Petition are routinely addressed in § 1983 19 actions. See Urlacher v. Lashaway, No. 16-CV-5912-RJB-JRC, 2017 WL 8942555 (W.D. Wash.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Michael Huftile v. L C Miccio-Fonseca
410 F.3d 1136 (Ninth Circuit, 2005)
Terry Dixon v. Renee Baker
847 F.3d 714 (Ninth Circuit, 2017)
Sharp v. Weston
233 F.3d 1166 (Ninth Circuit, 2000)
Leamer v. Fauver
288 F.3d 532 (Third Circuit, 2002)
Miranda v. Anchondo
684 F.3d 844 (Ninth Circuit, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Ollivier v. Devos, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ollivier-v-devos-wawd-2024.