Sanchez v. San Diego District Attorney

CourtDistrict Court, S.D. California
DecidedSeptember 18, 2025
Docket3:25-cv-02335
StatusUnknown

This text of Sanchez v. San Diego District Attorney (Sanchez v. San Diego District Attorney) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sanchez v. San Diego District Attorney, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JOSUE ISRAEL SANCHEZ, Case No.: 25cv2335 WQH (DEB)

12 Petitioner, ORDER DISMISSING CASE 13 v. WITHOUT PREJUDICE AND DENYING MOTION TO APPOINT 14 SAN DIEGO DISTRICT ATTORNEY, COUNSEL WITHOUT PREJUDICE 15 Respondent. [ECF No. 2] 16 17 HAYES, Judge: 18 On July 25, 2025, Petitioner Josue Israel Sanchez (“Petitioner”), a state inmate 19 proceeding pro se, filed a Petition for a Writ of Habeas Corpus pursuant to 28 U.S.C. 20 § 2254 in the Ninth Circuit Court of Appeals.1 (ECF No. 1.) Petitioner subsequently filed 21 a motion to appoint counsel in the Ninth Circuit. (ECF No. 2.) On September 8, 2025, the 22 Ninth Circuit issued an Order directing the transfer of the instant habeas Petition and 23 motion to this Court “for whatever consideration that court deems appropriate,” citing Fed. 24 25 1 While the instant Petition was transferred to this district after being initially sent to and 26 filed in the Ninth Circuit (see ECF Nos. 1 at 9, 1-2 at 1-2), the Court notes Petitioner has 27 captioned the Petition form to the San Diego Superior Court, North County. (See ECF No. 1 at 1.) That said, the Court will construe the Petition as one intended for filing in this Court 28 1 R. App. P. 22(a) and 28 U.S.C. §§ 1631, 2241(b), and stated that: “This transfer order is 2 issued without regard to whether petitioner’s claims have any merit or satisfy the 3 procedural requirements of 28 U.S.C. §§ 2244(d) and 2254.” (ECF No. 1-2 at 1-2.) The 4 Ninth Circuit also directed that: “The petition is deemed filed on July 25, 2025, the date it 5 was delivered to prison authorities for forwarding to this court.” (Id. at 1-2, citing Fed. R. 6 App. P. 4(c)(1) and Houston v. Lack, 487 U.S. 266, 270 (1988).) On September 2, 2025, 7 the instant case was opened as directed. See generally docket. For the reasons discussed 8 below, the Court dismisses the case without prejudice and denies the motion to appoint 9 counsel without prejudice. 10 FAILURE TO SATISFY FILING FEE REQUIREMENT 11 Petitioner has failed to pay the $5.00 filing fee and has failed to move to proceed in 12 forma pauperis. The Court cannot proceed until Petitioner has either paid the $5.00 filing 13 fee or has qualified to proceed in forma pauperis. See R. 3(a), Rules Governing Section 14 2254 Cases (2019). As such, the instant case is subject to dismissal for failure to satisfy the 15 filing fee requirement. 16 FAILURE TO NAME A PROPER RESPONDENT 17 In addition, Petitioner has failed to name a proper respondent. On federal habeas, a 18 state prisoner must name the state officer having custody of him as the respondent. Ortiz- 19 Sandoval v. Gomez, 81 F.3d 891, 894 (9th Cir. 1996), citing R. 2(a), Rules Governing 20 Section 2254 Cases (2019). Federal courts lack personal jurisdiction when a habeas petition 21 fails to name a proper respondent. See id. 22 The warden is the typical respondent. However, “the rules following section 2254 23 do not specify the warden.” Id. “[T]he ‘state officer having custody’ may be ‘either the 24 warden of the institution in which the petitioner is incarcerated . . . or the chief officer in 25 charge of state penal institutions.’” Id., quoting R. 2(a), Rules Governing Section 2254 26 Cases (2019), 28 U.S.C. foll. § 2254 advisory committee’s note. 27 Here, Petitioner has incorrectly named “San Diego District Attorney” as 28 Respondent. (See ECF No. 1 at 1.) In order for this Court to entertain the Petition filed in 1 this action, Petitioner must name the individual having custody of him as Respondent. 2 Brittingham v. United States, 982 F.2d 378, 379 (9th Cir. 1992) (per curiam); see also 3 Ashley v. Washington, 394 F.2d 125, 126 (9th Cir. 1968) (“The actual person who is [the] 4 custodian [of the petitioner] must be the respondent.”) Thus, the Petition is subject to 5 dismissal for failure to name a proper Respondent. 6 FAILURE TO EXHAUST STATE COURT REMEDIES 7 Upon review, it also does not appear state court remedies have been exhausted as to 8 any of the enumerated claims in the Petition. Habeas petitioners who wish to challenge 9 either their state court conviction or the length of their confinement in state prison must 10 first exhaust state judicial remedies. See 28 U.S.C. § 2254(b), (c); Granberry v. Greer, 481 11 U.S. 129, 133-34 (1987); see also Picard v. Connor, 404 U.S. 270, 275 (1971) (“[A] state 12 prisoner must normally exhaust available state judicial remedies before a federal court will 13 entertain his petition for habeas corpus.”) “A petitioner has satisfied the exhaustion 14 requirement if: (1) he has ‘fairly presented’ his federal claim to the highest state court with 15 jurisdiction to consider it,” which in this case is the California Supreme Court, “or (2) he 16 demonstrates that no state remedy remains available.” Johnson v. Zenon, 88 F.3d 828, 829 17 (9th Cir. 1996) (citations omitted); see also O’Sullivan v. Boerckel, 526 U.S. 838, 845 18 (1999) (“[S]tate prisoners must give the state courts one full opportunity to resolve any 19 constitutional issues by invoking one complete round of the State’s established appellate 20 review process.”) 21 Additionally, the claims presented in the federal courts must be the same as those 22 exhausted in state court and must also allege, in state court, how one or more of his federal 23 rights have been violated. See Picard, 404 U.S. at 276 (“Only if the state courts have had 24 the first opportunity to hear the claim sought to be vindicated in a federal habeas proceeding 25 does it make sense to speak of the exhaustion of state remedies. Accordingly, we have 26 required a state prisoner to present the state courts with the same claim he urges upon the 27 federal courts.”); see also Duncan v. Henry, 513 U.S. 364, 365-66 (1995) (“If state courts 28 are to be given the opportunity to correct alleged violations of prisoners’ federal rights, 1 they must surely be alerted to the fact that the prisoners are asserting claims under the 2 United States Constitution. If a habeas petitioner wishes to claim that an evidentiary ruling 3 at a state court trial denied him the due process of law guaranteed by the Fourteenth 4 Amendment, he must say so, not only in federal court, but in state court.”) 5 Petitioner raises two enumerated claims for relief, a claim alleging prosecutorial 6 misconduct and a claim alleging ineffective assistance of counsel. (See ECF No. 1 at 3-4.) 7 In order to proceed on federal habeas, Petitioner must first exhaust the claims he wishes to 8 present here in the California Supreme Court. Petitioner does not allege that he raised either 9 of the two claims he wishes to present here in the California Supreme Court, and instead 10 indicates he sought review in the state supreme court but that the issues raised in that court 11 are “not known.” (See id.

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Related

Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Houston v. Lack
487 U.S. 266 (Supreme Court, 1988)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Artuz v. Bennett
531 U.S. 4 (Supreme Court, 2000)
Mark Brittingham v. United States
982 F.2d 378 (Ninth Circuit, 1992)
Jackie Ervin Rasberry v. Rosie B. Garcia, Warden
448 F.3d 1150 (Ninth Circuit, 2006)
Duncan v. Henry
513 U.S. 364 (Supreme Court, 1995)

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Bluebook (online)
Sanchez v. San Diego District Attorney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanchez-v-san-diego-district-attorney-casd-2025.