Schaffer v. Clay

CourtDistrict Court, N.D. California
DecidedMarch 31, 2025
Docket5:24-cv-04103
StatusUnknown

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

Bluebook
Schaffer v. Clay, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 CRAIG RAYMOND SCHAFFER, Case No. 24-cv-04103-PCP

8 Plaintiff, ORDER DISMISSING PETITION IN PART, REQUIRING PETITIONER TO 9 v. FILE A RESPONSE TO THIS ORDER, AND DENYING MOTION TO 10 JENNIE CLAY, et al., PROCEED IN FORMA PAUPERIS 11 Defendants. Re: Dkt. Nos. 1, 7

12 Petitioner Craig Schaffer, a state prisoner proceeding pro se, has filed a petition for a writ 13 of habeas corpus under 28 U.S.C. § 2254. Dkt. No. 6. The Petition is now before the Court for 14 review pursuant to 28 U.S.C. § 2243 and Rule 4 of the Rules Governing Section 2254 Cases. Mr. 15 Schaffer also has filed a motion to dismiss the state charges, which appears duplicative of the 16 habeas petition, and a motion for permission to proceed in forma pauperis. Dkt. Nos. 1, 7. 17 Mr. Schaffer’s motion to proceed in forma pauperis is DENIED because the initial 18 assessment would exceed the filing fee for this habeas petition. 19 For the reasons given below, the Petition’s request for release and for interference in the 20 state criminal trial is DISMISSED, and the motion requesting release is DENIED. Mr. Schaffer 21 must wait until his state criminal proceedings have concluded before seeking relief from those 22 proceedings in a federal court. 23 If Mr. Schaffer wishes to challenge the conditions of his confinement, he must do so in a 24 civil rights action. Mr. Schaffer must notify the Court in writing whether he wishes the Court to 25 convert this habeas action to a civil rights action. 26 27 I. Discussion 1 custody pursuant to the judgment of a state court only on the ground that he is in custody in 2 violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a); Rose v. 3 Hodges, 423 U.S. 19, 21 (1975). A district court shall “award the writ or issue an order directing 4 the respondent to show cause why the writ should not be granted, unless it appears from the 5 application that the applicant or person detained is not entitled thereto.” 28 U.S.C. § 2243. 6 A. Release request 7 Mr. Schaffer asks for the criminal case against him to be dismissed, and for his release, 8 because he believes (1) his commitment became unlawful after he was found incompetent to stand 9 trial, (2) the incompetency finding was incorrect, and (3) his arrest followed entrapment, swatting, 10 illegal surveillance, stalking by an unidentified person, and “electronic warfare.” Pet. at 5. 11 The Petition reveals that Mr. Schaffer’s criminal trial is ongoing. See id. at 2 (showing Mr. 12 Schaffer has not yet had a criminal trial), 7 (asking this Court to dismiss the ongoing criminal case 13 in state superior court). In an abundance of caution, the Court searched the records of the 14 California state courts. These records confirmed that Mr. Schaffer’s criminal case is ongoing. See 15 People v. Schaffer, Case No. CRI-23020851 (San Francisco Cty. Super. Ct. filed Dec. 22, 2023). 16 The federal courts are required to abstain from considering Mr. Schaffer’s habeas petition 17 while it is ongoing, and until all state appeals have concluded. In Younger v. Harris, 401 U.S. 37 18 (1971), the United States Supreme Court held that principles of comity and federalism prohibit a 19 federal court from interfering with ongoing state criminal proceedings by granting injunctive or 20 declaratory relief absent extraordinary circumstances. See id. at 43–54. Circumstances which have 21 been found sufficiently “extraordinary” include the lack of an adequate legal remedy in state court 22 for the federal plaintiff, bias in the state court tribunal, and indefinite detention of the federal 23 plaintiff without a bail hearing or without counsel in the state action. See Mockaitis v. Harcleroad, 24 104 F.3d 1522, 1528 (9th Cir. 1997) (discussing the lack of an adequate remedy in state court); 25 Gibson v. Berryhill, 411 U.S. 564, 577–79 (1973) (concluding abstention was inappropriate due to 26 the state court judge’s bias); Arevalo v. Hennessy, 882 F.3d 763, 767 (9th Cir. 2018) (discussing 27 prolonged detention without a bail hearing); Betschart v. Oregon, 103 F.4th 607 (9th Cir. 2024) 1 counsel). Here, Mr. Schaffer does not complain of any such extraordinary circumstances. See 2 generally Pet. Under Younger, this Court cannot interfere in the state trial court’s criminal 3 proceedings. 4 Younger applies throughout appellate proceedings, requiring that state appellate review of 5 a state court judgment be exhausted before federal court intervention is permitted. See Dubinka v. 6 Judges of the Super. Ct., 23 F.3d 218, 223 (9th Cir. 1994). Younger requires abstention even if the 7 federal habeas petition attacks only the guilt phase of the petitioner’s trial, while the pending state 8 proceeding attacks only the penalty phase. See Edelbacher v. Calderon, 160 F.3d 582, 582–86 (9th 9 Cir. 1998). Thus, Mr. Schaffer cannot seek release from the federal court until his criminal trial 10 has concluded and he has unsuccessfully appealed to the First District Court of Appeal and to the 11 California Supreme Court. See 28 U.S.C. § 2254(b), (c) (explaining the exhaustion requirement); 12 Rose v. Lundy, 455 U.S. 509, 515–16 (1982) (same). 13 Mr. Schaffer’s claims for release and for dismissal of his criminal charges are 14 DISMISSED. This dismissal is without prejudice so that Mr. Schaffer may pursue a federal habeas 15 action once state proceedings have concluded. See 28 U.S.C. § 2244(d) (noting one-year statute of 16 limitations for filing of federal petition for writ of habeas corpus). 17 B. Medical claims 18 Mr. Schaffer also claims that he is being forcibly medicated and forced to undergo 19 “conversion therapy” related to his transgender identity, under which the “state hospital illegally 20 changed [his] sex back to female.” Pet. at 5. These claims do not concern a request for release, and 21 so are not barred by the Younger doctrine. See Bean v. Matteucci, 986 F.3d 1128, 1135–36 (9th 22 Cir. 2021) (holding Younger abstention was not required because the forcible administration of 23 antipsychotic medications on a pretrial detainee constitutes a particularly severe invasion of liberty 24 and the detainee’s right to avoid forcible administration of medications cannot be fully vindicated 25 after trial). 26 Although these claims are not barred by Younger, they cannot proceed in this habeas 27 action. “‘Federal law opens two main avenues to relief on complaints related to imprisonment: a 1 Rev.

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
WILWORDING Et Al. v. SWENSON, WARDEN
404 U.S. 249 (Supreme Court, 1971)
Gibson v. Berryhill
411 U.S. 564 (Supreme Court, 1973)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Hill v. McDonough
547 U.S. 573 (Supreme Court, 2006)
Ramirez v. Galaza
334 F.3d 850 (Ninth Circuit, 2003)
Rose v. Hodges
423 U.S. 19 (Supreme Court, 1975)
Damous Nettles v. Randy Grounds
830 F.3d 922 (Ninth Circuit, 2016)
Erick Arevalo v. Vicki Hennessy
882 F.3d 763 (Ninth Circuit, 2018)
Travis Bean v. Dolly Matteucci
986 F.3d 1128 (Ninth Circuit, 2021)
Mockaitis v. Harcleroad
104 F.3d 1522 (Ninth Circuit, 1997)
Betschart v. Washington County Circuit Court Judges
103 F.4th 607 (Ninth Circuit, 2024)

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Schaffer v. Clay, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schaffer-v-clay-cand-2025.