Rotchford v. State of Washington

CourtDistrict Court, W.D. Washington
DecidedOctober 28, 2024
Docket3:24-cv-05805
StatusUnknown

This text of Rotchford v. State of Washington (Rotchford v. State of Washington) 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
Rotchford v. State of Washington, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 FRASER MCDONOUGH ROTCHFORD, 9 Petitioner, CASE NO. 3:24-cv-05805-JLR-BAT 10 v. REPORT AND RECOMMENDATION FOR 11 STATE OF WASHINGTON, DISMISSAL 12 Respondent.

13 On September 9, 2024, Petitioner, Fraser McDonough Rotchford, filed a 28 U.S.C. § 14 2254 petition for writ of habeas corpus challenging his convictions in the Superior Courts of 15 Jefferson, Clallam, and King Counties. See Petition at Dkt. 1. The Clerk of Court sent Petitioner 16 a notice that the habeas petition was filed without paying the filing fee or an application to 17 proceed in forma pauperis (IFP), and that this is a deficiency Petitioner must cure by October 25, 18 2024, or the matter may be dismissed. 19 The Court has reviewed the habeas petition under Habeas Rule 4 of the Rules Governing 20 § 2254 habeas cases and finds the petition should be dismissed because: (1) Petitioner previously 21 filed a habeas petition challenging his King County conviction in this Court which was dismissed 22 as untimely and as presenting unexhausted claims; (2) Petitioner avers he did not appeal or seek 23 collateral review of the state convictions he challenges and his claims are thus unexhausted; (3) 1 Federal § 2254 habeas relief may be granted only if the state courts’ decisions that are challenged 2 were contrary to or involved an unreasonable application of clearly established Supreme Court 3 law, or if the state courts’ decisions were based upon an unreasonable determination of the facts. 4 The habeas petition fails to set forth any facts showing relief is warranted under § 2254; and (4)

5 Petitioner has neither paid the filing fee nor has he submitted a sufficient application to proceed 6 IFP. 7 DISCUSSION 8 The present § 2254 habeas petition indicates Petitioner challenges state convictions 9 involving “stalking, harassment, violation of an anti-harm [unintelligible] orders, threats to kill.” 10 Dkt. 1 at 1. As ground one for relief, Petitioner contends “The pretension of innocence based on 11 the violation of consent conflates the categorical imperative w/ representations.” Id. at 5. 12 Petitioner indicates he did not appeal or seek collateral review of this claim in the state courts. Id. 13 As ground two for relief, Petitioner contends: 14 My criminal record in its entirety limited to the state of Washington although I did get a restraining order from the 15 reincarnation of Marx in Alameda – b/c I wouldn’t fuck her in the butt is undermined by the fact I never legally left the Army – an 16 other than dishonorable discharge. I lied about # of times I used marijuana which undermines USC, USMC, Plator, Richards and 17 Parker E. Youngblood. 18 Id. at 6. Petitioner also indicates he was forced to take medications to gain competency in 19 violation of his right not to testify against himself and that the state prosecutors are liable for 20 transferring Petitioner from Clallam County without charges after Petitioner filed grievances 21 regarding the victim in the case. Id. at 9. The habeas petition further avers Petitioner did not 22 appeal or seek collateral relief of any of the state court convictions that he now challenges 23 herein. Id. 1 As an initial matter, the Court takes judicial notice1 that this is Petitioner’s third habeas 2 challenge to his King County Superior Court conviction. This Court’s records show Petitioner 3 filed a habeas petition in Rotchford v. State of Washington, 2:22-cv-00727-RSM challenging his 4 felony harassment conviction in King County Superior Court No. 17-1-01428-8. The Court

5 adopted the report and recommendation in this case and found Petitioner’s habeas challenge was 6 barred by the statute of limitations and presented unexhausted and defaulted claims because 7 Petitioner never appealed or sought the collateral review of the conviction in the state courts. The 8 Court dismissed the habeas petition on June 23, 2024. The Court also notes Petitioner filed a 9 habeas petition challenging his King County conviction on January 14, 2021 in Rotchford v. 10 Department of Corrections, 2:21-cv-00057-RJB. That petition was dismissed on June 2, 2021 for 11 failure to pay the filing fee or submit a sufficient IFP application. 12 As Petitioner’s habeas challenge to his King County conviction has been previously 13 determined by a judge in this Court as time-barred, unexhausted, and procedurally barred, 14 Petitioner may not reraise challenges to this conviction by filing yet another habeas petition as he

15 has done in this case. Under the doctrine of claim preclusion, a final judgment forecloses 16 “successive litigation of the very same claim, whether or not relitigation of the claim raises the 17 same issues as the earlier suit.” New Hampshire v. Maine, 532 U.S. 742, 748 (2001). Issue 18 preclusion, in contrast, bars “successive litigation of an issue of fact or law actually litigated and 19 resolved in a valid court determination essential to the prior judgment,” even if the issue recurs 20 21

22 1 Courts may take judicial notice of its own records and records in other cases. See Chandler v. United States, 378 F.3d 206, 900 (9th Cir. 1967) (Court “may take judicial notice of its own 23 records”); United States v. Howard, 381 F.3d 873, 876, n.1 (9th Cir. 2004) (Courts may “take judicial notice of court records in another case”). 1 in the context of a different claim. The Court accordingly dismisses with prejudice the present 2 habeas challenge to the King County conviction. 3 Petitioner also avers he did not appeal or file a petition for collateral relief in the state 4 courts challenging any of the state convictions that he mentions in the present habeas petition.

5 Petitioner may obtain federal habeas relief only if he has exhausted state judicial remedies. 6 Preiser v. Rodriguez, 411 U.S. 475, 500 (1973). The exhaustion requirement is a prerequisite to 7 the granting of a petition for writ of habeas corpus. 28 U.S.C. § 2254(b)(1)(A). See Rose v. 8 Lundy, 455 U.S. 509 (1982). The exhaustion doctrine is based on a policy of federal and state 9 comity that is designed to give state courts the initial opportunity to correct alleged constitutional 10 deprivations. See Picard v. Connor, 404 U.S. 270, 275 (1971). 11 The exhaustion doctrine requires a petitioner to do two separate things. First, to exhaust a 12 federal habeas claim, a petitioner must properly raise the federal claim in each appropriate state 13 court, including the state intermediate court of appeals and the state’s highest court. Baldwin v. 14 Reese, 541 U.S. 27, 29 (2004). And second, the exhaustion doctrine requires a petitioner to have

15 fully and fairly presented each federal habeas claim to the highest state court. Picard v. Connor, 16 404 U.S. at 275. 17 Here, Petitioner avers he has failed to present his habeas claims to the state courts via an 18 appeal or a petition for state collateral relief. As his claims are unexhausted, the Court should 19 dismiss them. 20 In addition to the two fatal deficiencies described above, the habeas petition fails to set 21 forth facts sufficient to state a claim for relief.

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Rotchford v. State of Washington, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rotchford-v-state-of-washington-wawd-2024.