Smith v. Unknown Party

CourtDistrict Court, D. Arizona
DecidedJune 2, 2020
Docket3:20-cv-08125
StatusUnknown

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

Bluebook
Smith v. Unknown Party, (D. Ariz. 2020).

Opinion

1 WO SC 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 Joshua Daniel Smith, No. CV 20-08125-PCT-MTL (JFM) 10 Petitioner, 11 v. ORDER 12 Unknown Party, 13 14 Respondent.

15 16 On May 28, 2020, Petitioner Joshua Daniel Smith, who is confined in a Mohave 17 County Jail, filed a pro se document captioned as “Special Action Habeas Corpus” 18 (“Petition”) (Doc. 1). The Clerk of Court opened a civil case to facilitate consideration of 19 the Petition and designated it as a petition under 28 U.S.C. § 2254, although Plaintiff did 20 not file the Petition on the court-approved form for use by prisoners and did not either pay 21 the $5.00 civil action filing fee or an Application to Proceed In Forma Pauperis (Habeas). 22 In the Petition, Petitioner seeks to challenge pending criminal proceedings in Mohave 23 County Superior Court. For that reason, the Court construes the Petition as seeking relief 24 under 28 U.S.C. § 2241. 25 The Court will dismiss the Petition with leave to file an amended petition using the 26 court-approved form petition. The Court will also grant Petitioner 30 days to either pay 27 the $5.00 filing fee or file an Application to Proceed In Forma Pauperis (Habeas). The 28 Court will direct the Clerk of Court to send Plaintiff the court-approved forms for a § 2241 1 habeas corpus petition and an application to proceed in forma pauperis. 2 I. Failure to Comply with Local Rule 3.5(b) 3 Rule 3.5(b) of the Local Rules of Civil Procedure requires that “[i]f a habeas corpus 4 petitioner desires to prosecute the petition in forma pauperis, the petitioner shall file an 5 application to proceed in forma pauperis on a form approved by the Court, accompanied 6 by a certification of the warden or other appropriate officer of the institution in which the 7 petitioner is confined as to the amount of money or securities on deposit to the petitioner’s 8 credit.” Rule 3.5(b) also requires payment of the $5.00 filing fee if a petitioner has in 9 excess of $25.00 in his inmate account. 10 Because Petitioner has not paid the $5.00 filing fee or filed an Application to 11 Proceed In Forma Pauperis, Petitioner will be given 30 days from the date this Order is 12 filed to either pay the $5.00 filing fee or file a complete Application to Proceed In Forma 13 Pauperis using the form included with this Order. 14 II. Pretrial Habeas Corpus Relief 15 Petitioner is attempting to seek pretrial relief as to his pending state criminal 16 charges. Challenges to pretrial incarceration may be properly brought pursuant to 28 17 U.S.C. § 2241. McNeeley v. Blanas, 336 F.3d 822, 824 n.1 (9th Cir. 2003). Section 18 2241(c)(3) provides that “the writ of habeas corpus [extends to persons who are] in custody 19 in violation of the Constitution or laws or treaties of the United States . . ..” However, 20 “federal habeas relief does not lie, absent ‘special circumstances,’ to adjudicate the merits 21 of an affirmative defense to a state criminal charge prior to a judgment of conviction by a 22 state court.” See Braden v. 30th Judicial Circuit Court of Kentucky, 410 U.S. 484, 489 23 (1973) (emphasis added); Carden v. Montana, 626 F.2d 82, 83-85 (9th Cir. 1980). 24 In addition, the abstention doctrine set forth in Younger v. Harris, 401 U.S. 37 25 (1971), prevents a federal court in most circumstances from directly interceding in ongoing 26 state criminal proceedings. The Younger abstention doctrine also applies while a case 27 works its way through the state appellate process, if a prisoner is convicted. New Orleans 28 Pub. Serv., Inc. v. Council of City of New Orleans, 491 U.S. 350, 369 (1989). Only in 1 limited, extraordinary circumstances will the Younger doctrine not bar federal interference 2 with ongoing (non-final) state criminal proceedings. Such circumstances include when a 3 prisoner alleges that he is being subjected to double jeopardy. See Mannes v. Gillespie, 4 967 F.2d 1310, 1312 (9th Cir. 1992). Speedy trial claims may also be reviewed if a detainee 5 is seeking to compel the state to bring him to trial, rather than seeking dismissal of the 6 charges, and the detainee has exhausted all his state court remedies. Braden, 410 U.S. at 7 489-90; see In re Justices of Superior Court Dep’t of Mass. Trial Court, 218 F.3d 11, 18 8 & n.5 (1st Cir. 2000); Carden, 626 F.2d at 83-85 (explaining that for reasons of comity, a 9 pretrial detainee must show special circumstances, in addition to the merits of a speedy 10 trial claim, warranting federal intervention in state criminal proceedings and noting that 11 “unlike the Double Jeopardy Clause, the Speedy Trial Clause, when raised as an affirmative 12 defense, does not embody a right which is necessarily forfeited by delaying review until 13 after trial.”); see Politano v. Miller, No. Civil 08-238, 2008 WL 906300, at *4-5 (D. Minn. 14 Mar. 31, 2008) (finding alleged speedy trial violation did not constitute special 15 circumstance within Braden where petitioner sought dismissal of criminal charges, rather 16 than immediate trial, and had not exhausted claim). 17 III. Petition not on Court-Approved Form 18 Pursuant to Rule 3.5(a) of the Local Rules of Civil Procedure, Petitioner is required 19 to use a court-approved form when he files a pro se petition pursuant to 28 U.S.C. § 2241. 20 The Court may, in its discretion, forgo the requirement that a petitioner use a court- 21 approved form. See LRCiv 3.5(a). The Court will require use of the court-approved form 22 because Petitioner’s Petition does not substantially comply with the court-approved form. 23 The Court will dismiss the Petition without prejudice and with leave to file an amended 24 petition within 30 days. 25 IV. Leave to Amend 26 Within 30 days, Petitioner may submit an amended petition on the court-approved 27 form. The Clerk of Court will mail Petitioner a court-approved form to use for filing a 28 § 2241 Petition. If Petitioner fails to use the court-approved form, the Court may strike the 1 amended petition and dismiss this action without further notice to Petitioner. 2 Petitioner’s amended petition should clearly set out each claim Petitioner is making. 3 If Petitioner cannot fit all his supporting facts or arguments in favor of a particular ground 4 on the court-approved form, then he may continue on an attachment, but each matter on 5 any attachment must be clearly referenced to a particular ground on the court-approved 6 form. 7 Petitioner is advised that the amended petition must be retyped or rewritten in its 8 entirety on the court-approved form and may not incorporate any part of the original 9 Petition by reference. Any amended petition submitted by Petitioner should be clearly 10 designated as such on the face of the document. 11 An amended petition supersedes the original Petition. Ferdik v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Smith v. Unknown Party, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-unknown-party-azd-2020.