Rod Anthony Huff v. Los Angeles County Superior Court

• Court: District Court, C.D. California
• Decided: June 10, 2024
• Docket: 2:24-cv-04115
• Status: Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 ROD A. HUFF JR., Case No. CV 24-04115 AB (RAO) 12 Petitioner, 13 ORDER DISMISSING ACTION v. 14 LOS ANGELES COUNTY 15 SUPERIOR COURT, 16 Respondent. 17 18 I. INTRODUCTION 19 On April 25, 2024, Rod A. Huff, Jr. (“Petitioner”), a pretrial detainee 20 proceeding pro se, constructively filed a Petition for Writ of Habeas Corpus 21 (“Petition”) pursuant to 28 U.S.C. § 2241.1 (ECF No. 1 (“Pet.”).) At the time of 22 constructively filing, Petitioner was being held in a jail in Los Angeles County.2 23 24 25 1 The Petition was originally filed in the Ninth Circuit and subsequently transferred to this district on May 8, 2024. (See ECF No. 2.) Pursuant to the Ninth Circuit’s 26 transfer order, the Petition is deemed filed on April 25, 2024, the date it was signed. 27 (Id.) 2 Petitioner filed a notice of change of address on May 28, 2024, listing Patton State 28 Hospital as his new address. (ECF No. 7.) 1 The Petition alleges violations of the Fourth and Eighth Amendments, the 2 Eminent Domain Clause of the Fifth Amendment, and the Uniform Commercial 3 Code. (Pet. at 3–4.)3 Attached to the Petition are copies of the initial and 4 supplemental case reports from the Beverly Hills Police Department underlying his 5 criminal case in the Los Angeles County Superior Court, People v. Rod Anthony 6 Huff, Jr., Case No. SA109037 (filed October 31, 2023), a memorandum dated 7 March 21, 2024, from the California Office of Patients’ Rights accompanied with a 8 psychiatric evaluation from the Department of State Hospitals; and correspondence 9 from the superior court. (Pet. at 10–15 (police report), 16 (memorandum), 17-19 10 (psychiatric evaluation); ECF No. 1-1 at 2 (correspondence).) 11 Because Petitioner’s criminal cases4 are ongoing, the Court must abstain 12 under Younger v. Harris, 401 U.S. 37 (1971), and dismiss the Petition without 13 prejudice. 14 II. DISCUSSION 15 Federal courts must abstain from interfering in pending state proceedings 16 absent extraordinary circumstances that create a threat of irreparable injury. 17 Younger, 401 U.S. at 45–46. Abstention under Younger is warranted where the 18 state proceedings (1) are ongoing; (2) implicate important state interests; and (3) 19 provide an adequate opportunity to litigate the petitioner’s federal constitutional 20 claims. Middlesex Cty. Ethics Comm. V. Garden State Bar Ass’n, 457 U.S. 423, 21 432 (1982); Dubinka v. Judges of Super. Ct. of State of Cal., 23 F.3d 218, 223 (9th 22 Cir. 1994). A claimant may avoid application of the Younger abstention doctrine 23 by demonstrating that there is bad faith, harassment, or some other extraordinary 24 25 3 The Court will use the page numbers assigned by the ECF system for the Petition and its attachments. 26 4 The Petition states Petitioner is in custody for two state criminal cases in Los 27 Angeles County Superior Court: case nos. SA102645 and SA109037-01. (Pet. at 2.) Further, the Court notes that Petitioner lists San Bernardino County Superior Court 28 case no. WHC5B2400041 on the first page of the Petition. (Pet. at 1.) 1 circumstance where irreparable injury can be shown. See Perez v. Ledesma, 401 2 U.S. 82, 85 (1971). 3 First, this Court takes judicial notice of the docket of the Los Angeles County 4 Superior Court,5 which shows that Petitioner’s criminal matters remain pending. 5 See Criminal Case Access, https://www.lacourt.org/criminalcasesummary/ui/ (last 6 visited June 6, 2024). The pendency of the matters before the superior court weighs 7 in favor of abstention. See Drury v. Cox, 457 F.2d 764, 764–65 (9th Cir. 1972) 8 (stating that only in the most unusual circumstances is a defendant entitled to have 9 federal interposition by way of injunction or habeas corpus until after a judgment 10 has been appealed from, and the case has been concluded in state courts). 11 Second, the state proceedings implicate important state interests, particularly 12 the State of California’s interest in the order and integrity of its criminal 13 proceedings. See Kelly v. Robinson, 479 U.S. 36, 49 (1986) (“[T]he States’ interest 14 in administering their criminal justice systems free from federal interference is one 15 of the most powerful of the considerations that should influence a court considering 16 equitable types of relief.”). Accordingly, the second Younger factor weighs in favor 17 of abstention. 18 Third, Petitioner has an adequate opportunity to raise any federal habeas 19 claims in his pending state proceedings. See Pennzoil Co. v. Texaco, Inc., 481 U.S. 20 1, 15, 107 S. Ct. 1519, 95 L. Ed. 2d 1 (1987) (finding that a federal court should 21 assume that state procedures will afford adequate opportunity for consideration of 22 constitutional claims “in the absence of unambiguous authority to the contrary”). 23 Therefore, the final Younger factor also weighs in favor of abstention. 24 Finally, Petitioner has not alleged facts showing bad faith, harassment, 25 extraordinary circumstances, or irreparable injury. Because all three criteria for 26 27 5 See Fed. R. Evid. 201; Harris v. Cty. of Orange, 682 F.3d 1126, 1131–32 (9th Cir. 2012) (holding a district court may take judicial notice of undisputed matters of 28 public record including documents on file in federal or state courts). 1 || Younger abstention apply and there is no compelling reason for federal intervention 2 || at this time, the Court abstains from interfering with Petitioner’s pending state 3 || criminal proceedings. See Middlesex, 457 U.S. at 435. 4 I. CONCLUSION 5 IT IS ORDERED that the Petition is dismissed without prejudice. 6 7 || DATED: June 10, 2024 | , 7 8 9 ANDRE BIROTTE JR. 10 UNITED STATES DISTRICT JUDGE

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