Shunn v. Davis

CourtDistrict Court, D. Idaho
DecidedSeptember 9, 2022
Docket1:22-cv-00258
StatusUnknown

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

Bluebook
Shunn v. Davis, (D. Idaho 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

FORREST GLENN SHUNN, Case No. 1:22-cv-00258-REP Petitioner, INITIAL REVIEW ORDER v.

T. DAVIS and S. WESSELER,

Respondents.

Petitioner Forrest Glenn Shunn has filed a Petition for Writ of Habeas Corpus challenging Petitioner’s state court convictions. See Dkt. 4. The Court now reviews the Petition to determine whether it is subject to summary dismissal pursuant to 28 U.S.C. § 2243 and Rule 4 of the Rules Governing Section 2254 Cases (“Habeas Rules”). REVIEW OF PETITION 1. Standard of Law for Review of Petition Federal habeas corpus relief under 28 U.S.C. § 2254 is available to petitioners who show that they are held in custody under a state court judgment and that such custody violates the Constitution, laws, or treaties of the United States. See 28 U.S.C. § 2254(a). The Court is required to review a habeas corpus petition upon receipt to determine whether it is subject to summary dismissal. Habeas Rule 4. Summary dismissal is appropriate where “it plainly appears from the face of the petition and any attached exhibits that the petitioner is not entitled to relief in the district court.”1 Id. 2. Discussion

Petitioner pleaded guilty to grand theft, possession of a controlled substance, and burglary In the First Judicial District Court in Kootenai County, Idaho. The judgment of conviction was entered in September 2018. Petitioner pursued a direct appeal as well as state post-conviction relief. Pet. at 1–3. The Court construes the Petition as asserting the following claims.2 Claim 1(a)

appears to assert that the trial court should have granted a mistrial based on false information regarding the date of the judgment. Claim 1(b) alleges that Petitioner’s guilty plea was coerced by his defense attorney. In Claim 1(c), Petitioner appears to allege that he is innocent of the crimes for which he was convicted. Id. at 6 (“I didn’t take tools or commit grand theft ….”).

Claim 2 asserts “wrongful use of existing evidence.” Id. at 7. Petitioner alleges that unidentified officials conspired against him in the use of this evidence.

1 However, a court undertaking a Rule 4 review is not required to comb through a petitioner’s exhibits or other documents—such as memoranda, affidavits, or the petitioner’s state court briefing—to determine whether a petitioner may proceed past initial screening. Nor is a respondent required to consider or address such documents when responding to the petition. This is because, under Habeas Rule 2(c), the petition must “specify all the grounds for relief available to petitioner” and “state the facts supporting each ground.” That is, a habeas petitioner must include—in the petition itself—“all of the information necessary to adjudicate that Petition.” Sivak v. Christensen, No. 1:16-CV-00189-BLW, 2018 WL 4643043, at *2 n.3 (D. Idaho Sept. 27, 2018) (unpublished). Therefore, the Court has considered only the Petition itself (Dkt. 4) in its Rule 4 review, not Petitioner’s numerous affidavits and letters. See Dkt. 14 through 18. 2 If the Court’s construction of any claim is incorrect, Petitioner must inform the Court and Respondent of all corrections within 28 days after entry of this Order. For ease of reference, the Court uses alphanumeric identifiers for Petitioner’s sub-claims. In Claim 3(a), Petitioner alleges that he has had “false cases” added to “old cases.” Id. at 8. It appears Petitioner is alleging that the prosecutor pursued additional charges of petty theft and then threatened Petitioner with a warrant on those charges unless

Petitioner paid a sum of money. This sub-claim might be challenging a restitution order, but that is not entirely clear. Claim 3(b) alleges that Petitioner “had [his] rape lied about” and that officials did not ensure that a rape kit was performed. Id. Claim 4(a) appears to assert tort claims based on actions (or inaction) of the Ada

County Clerk of Court. Petitioner alleges that he sent two filing fees to the Ada County Court but that he received no response. Id. at 9. In Claim 4(b), Petitioner appears to allege that prison officials conducted an inadequate investigation into his rape. Id. at 10. This sub-claim appears related to Claim 3(b).

Petitioner may proceed on the Petition to the extent that the claims (1) are cognizable—meaning they actually can be heard—in a federal habeas corpus action, (2) were timely filed in this Court, and (3) were either properly exhausted in state court or are subject to a legal excuse for any failure to exhaust in a proper manner. At this time, the Court expresses no opinion as to whether any of these issues applies to any of

Petitioner’s claims. It is necessary for the Court to review portions of the state court record to resolve preliminary procedural issues, and it would also be helpful to receive briefing from Respondent. Therefore, the Court will order the Clerk to serve a copy of the Petition on counsel for Respondent, who may respond either by answer or pre-answer motion and who will provide relevant portions of the state court record to this Court. 3. Potentially Applicable Standards of Law

Because Petitioner does not have a lawyer and because the Court finds that focused briefing from the parties would be beneficial in this case, the Court provides the following standards of law that might, or might not, be applicable to Petitioner’s case. A. Potentially Non-Cognizable Claims The Court will not dismiss any claims at this early stage of the proceedings, but it notes that some of Petitioner’s claims may be subject to dismissal at a later date as non-

cognizable in this habeas corpus case. As stated earlier, federal habeas corpus relief is available if the petitioner “is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a) (emphasis added). That is, only federal claims may be raised in habeas corpus. “[F]ederal habeas corpus relief does not lie for errors of state law.” Lewis v.

Jeffers, 497 U.S. 764, 780 (1990). Petitioner does not expressly cite a federal basis for his habeas claims. Claim 1(b) can be construed as asserting that Petitioner’s guilty plea was not knowing, intelligent, and voluntary in violation of the Due Process Clause, and Claim 3(a) can perhaps be construed as asserting prosecutorial misconduct. However, Claims 1(a), 2, and 4(a) do

not appear to rely on any provision of the federal Constitution or other federal law or treaty. Rather, these claims appear to rely on Idaho state law governing mistrials, admission of evidence, and torts. Thus, unless Petitioner amends his petition to assert a federal basis for these claims, they may be dismissed at a later date as noncognizable.3 Additionally, Claims 3(b) and 4(b) appear to be federal civil rights claims, which

generally are not cognizable in federal habeas proceedings. “[T]he essence of habeas corpus is an attack by a person in custody upon the legality of that custody,” and “the traditional function of the writ is to secure release from illegal custody.” Preiser v. Rodriguez, 411 U.S. 475, 484 (1973); see also Badea v. Cox, 931 F.2d 573, 574 (9th Cir. 1991) (“Habeas corpus proceedings are the proper mechanism for a prisoner to challenge

the ‘legality or duration’ of confinement.”) (quoting Preiser, 411 U.S.

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Shunn v. Davis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shunn-v-davis-idd-2022.