Robert James v. Jeff Macomber, Secretary, et al.

District Court, S.D. California·Decided June 29, 2026·No. 3:25-cv-03292·Unknown

Opinion

ROBERT JAMES, Case No.: 3:25-cv-3292-JES-SBC

Petitioner, ORDER GRANTING MOTION TO v. DISMISS PETITION FOR A WRIT OF HABEAS CORPUS AND JEFF MACOMBER, Secretary, et al., DENYING A CERTIFICATE OF Respondent. APPEALABILITY [ECF No. 7] Robert James (“Petitioner”) is a state prisoner proceeding pro se and in forma pauperis with a Petition for a Writ of Habeas Corpus filed under 28 U.S.C. § 2254 challenging his 2020 parole denial by the California Board of Parole Hearing (“BPH”), the subsequent state court denial of his petitions, and his continued incarceration pursuant to a 1995 judgment of conviction in San Diego Superior Court case number SCD105774 for which he is serving an indeterminate life sentence. ECF No. 1. Respondent has filed a motion to dismiss and lodged relevant portions of the state record. ECF Nos. 7-8. Petitioner has filed an opposition to the motion to dismiss.1 ECF No. 9. 1 Although this case was referred to United States Magistrate Judge Steve B. Chu pursuant The following procedural history is taken from the state appellate court decision in In re Robert A. James on Habeas Corpus, D084706 (Cal. Ct. App. Sept. 24, 2024). See ECF No. 8-4. In 1995, a jury found petitioner Robert A. James guilty of assault with a deadly weapon (Pen. Code, §§ 245, subd. (a) & 1192.7, subd. (c)(23); count 1); commercial burglary (Pen. Code, § 459; count 2); two counts of petty theft with priors (Pen. Code, §§ 484, 666; counts 3 & 4); and misdemeanor simple battery (Pen. Code, § 242; count 5). The court found true two serious felony prior convictions (Pen. Code, § 667, subd. (a)(1)); two prison priors (Pen. Code, § 667.5, subd. (b)); and two serious/violent felony priors (Pen. Code, § 667, subds. (b)-(i)). The court originally sentenced James to a total term of 75 years to life in state prison, comprised of three consecutive terms of 25 years to life on counts 1, 3, and 4.

In the direct appeal, this court affirmed the judgment but ordered James’s sentence modified to add five years for each of the two serious felony priors. (People v. James (Nov. 21, 1996, D023261) [nonpub. opn.].) Accordingly, James was resentenced to 85 years to life. The modified judgment was affirmed on further appeal by this court. (People v. James (Nov. 17, 2000, D034933) [nonpub. opn.].)

In 2015, the trial court granted James’s petition for resentencing pursuant to Penal Code sections 1170.18 and 1170.126 and resentenced James to an aggregate term of 35 years to life after reinstating his sentence of 25 years to life on count 1 and imposing five-year terms for each of his serious felony priors. This court affirmed the resentencing order. (People v. James (Mar. 24, 2016, D069142) [nonpub. opn.].) On July 7, 2020, the Board of Parole Hearings (the Board) found James unsuitable for parole and denied parole for seven years. On March 22, 2022, James filed a petition to advance his parole hearing date, contending he was now eligible for consideration under the Elderly Parole Program. On November 1, 2023, the Board denied James’s petition to advance after finding Recommendation nor oral argument are necessary for disposition of this matter. See S.D. James failed to establish a change in circumstances or new information as required by Penal Code section 3041.5, subd. (d)(2).

ECF No. 8-4 at 1-2 (brackets in original).2 On February 11, 2024, Petitioner constructively filed a habeas petition in the San Diego County Superior Court, alleging that his continued incarceration had become excessive in violation of the Eighth Amendment, the BPH violated equal protection when it issued him a 7-year parole denial and the BPH violated due process in denying his petition to advance.3 ECF No. 8-1 at 3-5, 103. On June 20, 2024, the superior court denied that petition in a reasoned decision.4 ECF No. 8-2 at 2, 9. On August 20, 2024, Petitioner constructively filed a habeas petition in the California Court of Appeal, in which he contended the superior court violated his due process rights by failing to order informal briefing and “illegally interposed itself as Respondent by issuing a unilateral summary denial,” made an unconstitutionally vague

2 It appears from the lodgments that Petitioner’s petition to advance was instead postmarked on November 1, 2023, received November 3, 2023, and denied on November 13, 2023, see ECF No. 8-1 at 25-26, while on March 22, 2022, Petitioner was found to have met “court ordered elderly offender criteria” providing for earlier parole consideration. Id. at 14. However, the apparent discrepancies in dates of the receipt and denial of the petitions to advance are ultimately immaterial to the outcome of the instant motion to dismiss for the reasons discussed below.

3 While the superior court habeas petition is filed-stamped February 20, 2024, the constructive filing date for federal habeas purposes is February 11, 2020, the date Petitioner submitted it for mailing to the Court. See ECF No. 8-1 at 1, 103; see Stillman v. LaMarque, 319 F.3d 1199, 1201 (9th Cir. 2003) (“Under the ‘mailbox rule,’ a pro se prisoner’s filing of a state habeas petition is deemed filed at the moment the prisoner delivers it to prison authorities for forwarding to the clerk of the court.”) 4 The superior court’s denial is dated June 20, 2024, see ECF No. 8-2 at 2, 9, and the certificate of service by mail is dated June 27, 2024. See ECF No. 8-2 at 1. While the difference in dates do not materially impact the outcome of the instant motion, the Court will in an abundance of caution utilize the latter service date (to Petitioner’s benefit) in the decision, and violated equal protection and the intent of Proposition 57, the latter of which required BPH consideration yearly, and in which Petitioner incorporated by reference and attachment the claims previously raised in the superior court. ECF No. 8-3 at 1, 3-6, 121. On September 24, 2024, the California Court of Appeal denied the habeas petition in a reasoned decision. ECF No. 8-4. On April 3, 2025, Petitioner constructively filed a habeas petition in the California Supreme Court, again incorporating the arguments and claims presented in his prior petitions, contending that the superior and appellate courts violated due process in the state habeas corpus procedures, again citing the lack of informal briefing and asserting the state appellate court failed to address several federal issues presented. ECF No. 8-5 at 1, 5-14, 23, 281. On August 27, 2025, the California Supreme Court summarily denied the habeas petition without a statement of reasoning or citation to authority. See ECF No. 8-6. On November 6, 2025, Petitioner constructively filed the instant federal Petition.5 ECF No. 1 at 1, 2. Here, Petitioner contends that his continued incarceration has become constitutionally excessive in violation of the Eighth Amendment (ground one), the state superior and appellate courts violated federal due process safeguards by erring in rendering their decisions rejecting his petitions and failing to first order statutorily required briefing (ground two), and California’s “some evidence” standard is constitutionally deficient and the State failed to protect his state created liberty interest in parole (ground three); Petitioner also argues that the BPH erred and violated his due process rights in their 2020 parole denial (ground four) and in the later 2023 denial of his petition to advance (ground

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Robert James v. Jeff Macomber, Secretary, et al., (S.D. Cal. 2026).

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