Sean Jones v. T. Jury

CourtDistrict Court, C.D. California
DecidedNovember 5, 2020
Docket5:20-cv-02247
StatusUnknown

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

Bluebook
Sean Jones v. T. Jury, (C.D. Cal. 2020).

Opinion

CIVIL MINUTES – GENERAL

Case No.: 5:20-cv-02247-SVW-MAA Date: November 5, 2020 Title: Sean Jones v. T. Jury et al.

Present: The Honorable MARIA A. AUDERO, United States Magistrate Judge

James Muñoz N/A Deputy Clerk Court Reporter / Recorder

Attorneys Present for Plaintiff: Attorneys Present for Defendants: N/A N/A

Proceedings (In Chambers): Order re: Filing of Petition

On September 29, 2020, Petitioner Sean Jones (“Petitioner”), a federal inmate currently incarcerated at United States Penitentiary-Victorville, filed a pro se petition for writ of habeas corpus pursuant to 28 U.S.C. § 2241 (“Section 2241”) (“Petition”) in the United States District Court for the Southern District of New York. (Pet., ECF No. 1.) The Petition was transferred to this Court on October 19, 2020. (ECF No. 2.)

Petitioner raises several claims stemming from an incident on June 8, 2020 when Petitioner allegedly suffered a severe fall while walking up the stairs on his way back to his cell after showering. (Pet. 3–4.) He alleges that prison guards mistreated him and falsified disciplinary charges, challenges his conditions of confinement and denial of medical treatment, and seeks $500,000 in damages. (Id. at 3–8.)

Petitioner recently filed another 2241 Petition in this Court that raises largely identical claims. See Pet., Jones v. Jury, No. 2:20-cv-08771-SVW-MAA (“Jones I”) (filed Sept. 23, 2020), ECF No. 1. However, the Petition raises a new claim against K. Dorsey, “the mental health lady,” alleging that Dorsey suggested Petitioner intentionally hurt himself, and that Petitioner was denied mental health treatment. (Pet. 2, 8.) Further, the Jones I Petition contains allegations regarding Petitioner’s disciplinary charges and his conditions of confinement in the Special Housing Unit are not included in the instant Petition. (Jones I Pet. 5–6.) Accordingly, the Court cannot treat the instant Petition as duplicative or construe it as an amended petition in Jones I.

The Petition suffers from certain procedural defects that must be resolved before Petitioner may proceed with this action. These defects are listed below. The Court ORDERS Petitioner to respond to the following issues by no later than December 7, 2020. CIVIL MINUTES – GENERAL

Case No.: 5:20-cv-02247-SVW-MAA Date: November 5, 2020 Title: Sean Jones v. T. Jury et al.

Lack of Habeas Jurisdiction

Rule 4 of the Rules Governing Section 2254 Cases in the United States District Courts (“Habeas Rules”) requires summary dismissal of federal habeas petitions “[i]f it plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief in the district court.” See also Habeas Rule 1(b) (applying the Habeas Rules to habeas actions brought pursuant to Section 2241).

Relief in the form of a writ of habeas corpus may be granted to a person in custody under the authority of the United States if the petitioner can show that he is “in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2241(c)(1), (3). In general, habeas proceedings provide a forum in which to challenge the “legality or duration” of a prisoner’s confinement. Crawford v. Bell, 599 F.2d 890, 891 (9th Cir. 1979); see also Preiser v. Rodriguez, 411 U.S. 475, 484 (1973) (“[T]he essence of habeas corpus is an attack by a person in custody upon the legality of that custody . . . .”); Tucker v. Carlson, 925 F.2d 330, 331 (9th Cir. 1991) (concluding that challenges to “the manner in which [a] sentence was executed,” or to “the fact or duration of . . . confinement,” are properly brought in habeas petitions pursuant to Section 2241). A habeas corpus petition brought pursuant to Section 2241 is the proper vehicle for a federal inmate’s challenge to the manner, location, or conditions of a sentence’s execution. Hernandez v. Campbell, 204 F.3d 861, 864 (9th Cir. 2000). To the extent a federal inmate challenges his conditions of confinement, or to the extent the inmate seeks damages or injunctive relief for civil rights violations, the inmate’s claims are properly brought pursuant to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971) (“Bivens”). See Badea v. Cox, 931 F.2d 573, 574 (9th Cir. 1991); Tucker, 925 F.2d at 332.

In this case, Petitioner appears to challenge only his conditions of confinement and alleged misconduct by correctional officers. (See Pet. 3–8.) Although he alleges that he faced falsified disciplinary charges, he does not explain what effect, if any, these charges have had on the duration of his confinement (for example, by alleging a loss of good time credits). (See id. at 6–7.) Petitioner seeks $500,000 in damages and does not request any relief relating to his release from confinement. (See id. at 7.)

The Court generally has discretion to construe a habeas petition as a civil rights complaint. See Wilwording v. Swenson, 404 U.S. 249, 251 (1971), superseded by statute on other grounds as CIVIL MINUTES – GENERAL

Case No.: 5:20-cv-02247-SVW-MAA Date: November 5, 2020 Title: Sean Jones v. T. Jury et al. stated in Woodford v. Ngo, 548 U.S. 81, 84 (2006). However, it is not clear that such recharacterization would be appropriate in this case.

First, Petitioner has not authorized the $350 filing fee for a civil rights case to be deducted from his prison trust account pursuant to 28 U.S.C. § 1915(b). Instead, Petitioner requested that the $5 filing fee for a habeas action be withdrawn from his account. (Pet. 8.) The Court cannot presume that Petitioner would continue to pursue this action if he knew he ultimately would be obliged to pay the $350 filing fee regardless of the outcome of his case.

Second, the Court would be obligated to screen the converted Petition under 28 U.S.C. § 1915A to determine whether the complaint is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. If the converted Petition ultimately were to be dismissed on the basis that it is frivolous, malicious, or fails to state a claim, that dismissal would count as a “strike” against Petitioner with respect to 28 U.S.C. § 1915(g), which provides that a prisoner who has three “strikes” may not bring an action or appeal without prepayment of the full filing fee “unless the prisoner is under imminent danger of serious physical injury.”

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Related

WILWORDING Et Al. v. SWENSON, WARDEN
404 U.S. 249 (Supreme Court, 1971)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Rumsfeld v. Padilla
542 U.S. 426 (Supreme Court, 2004)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Marion Calvin Tucker v. Peter Carlson, Warden
925 F.2d 330 (Ninth Circuit, 1991)
John Badea v. Harvey Cox
931 F.2d 573 (Ninth Circuit, 1991)
Johnson v. Reilly
349 F.3d 1149 (Ninth Circuit, 2003)
Hernandez v. Campbell
204 F.3d 861 (Ninth Circuit, 2000)

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Bluebook (online)
Sean Jones v. T. Jury, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sean-jones-v-t-jury-cacd-2020.