Sosa v. Bird

CourtDistrict Court, S.D. California
DecidedApril 2, 2025
Docket3:22-cv-01022
StatusUnknown

This text of Sosa v. Bird (Sosa v. Bird) 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
Sosa v. Bird, (S.D. Cal. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF CALIFORNIA 3 4 Jorge Luis SOSA, Case No.: 22-cv-1022-AGS-BLM

5 Petitioner, ORDER ACCEPTING REPORT AND 6 v. RECOMMENDATION (ECF 7) AND DENYING HABEAS PETITION 7 O’Brian BAILEY, Warden, et al., (ECF 1) 8 Respondents. 9 10 In this petition for a writ of habeas corpus, petitioner seeks relief from his state 11 child-molestation convictions. 12 BACKGROUND 13 After a California state-court trial, petitioner Jorge Sosa was convicted of 26 counts 14 of molestation-related felonies involving two boys. People v. Sosa, No. D076457, 2021 15 WL 220109, at *2, *4 (Cal. Ct. App. Jan. 22, 2021). The specific crimes involved “oral 16 copulation with a child 10 years or younger,” “forcible lewd or lascivious acts on a child 17 under 14 years,” and “aggravated sexual assault of a child under 14 years.” Id. The 18 California Court of Appeal affirmed those convictions, id. at *11, and the state Supreme 19 Court declined further review (ECF 5-6, at 1). Sosa now requests federal habeas relief. 20 The state appellate court’s recitation of the facts—which is “presumed to be correct” 21 absent “clear and convincing evidence” to the contrary, see 28 U.S.C. § 2254(e)(1)—is 22 straightforward. In early 2011, “Sosa’s niece Ivon” moved in with Sosa, along with her 23 five children, including the alleged minor victims, her “two sons, IP and LS.” Sosa, 24 2021 WL 220109, at *1. “At some point after they moved into the house, Sosa began 25 molesting IP.” Id. at *2. “IP generally remembered that it happened throughout middle 26 school, but he also recalled incidents from the period when his family lived with Sosa and 27 after they moved out” in 2013. Id. at *1–2. IP “could have been as young as eight when the 28 abuse started.” Id. at *2. “It continued until mid-2016[] and was only disrupted because IP 1 moved to Los Angeles to live with his father.” Id. “After that, Sosa turned his attention to 2 LS,” who was “about twelve years old at the time.” Id. 3 In his habeas petition, Sosa advances three arguments: (1) his due-process rights 4 were violated by the “wide-ranging time periods alleged by the prosecution” in the 5 charging document, (2) the evidence is “insufficient” to sustain his conviction, and (3) the 6 cumulative effect of the errors violated due process. (ECF 1, at 7–17.) The magistrate judge 7 recommended rejecting each of these claims. (See generally ECF 7.) Sosa objected to this 8 recommendation in its entirety (see ECF 9), so this Court considers the matter “de novo.” 9 See 28 U.S.C. § 636(b)(1). In particular, this Court must examine the California Court of 10 Appeal’s opinion, as it is “the state’s last reasoned decision.” See Avila v. Galaza, 297 F.3d 11 911, 918 (9th Cir. 2002). 12 DISCUSSION 13 A. Due Process 14 In his state-court appeal, Sosa raised a constitutional challenge to the “broad time 15 periods associated with his convictions.” Sosa, 2021 WL 220109, at *4. Sosa argued that 16 the date ranges of the alleged abuse, “some of which exceed[ed] five years,” “denied him 17 due process because they prevented him from mounting an effective defense.” Id. The 18 Court of Appeal noted that “the primary authority on this point . . . suggests a contrary 19 conclusion,” but ultimately did not reach that question, holding that “Sosa forfeited this 20 claim” by failing to timely raise it in the trial court. Id. at *4–5. 21 Federal courts “will not review a question of federal law by a state court,” such as 22 Sosa’s due-process claim, “if the decision of that court rests on a state law ground that is 23 independent of the federal question and adequate to support the judgment.” Coleman v. 24 Thompson, 501 U.S. 722, 729 (1991). This doctrine “ensures that the States’ interest in 25 correcting their own mistakes is respected in all federal habeas cases.” Id. at 732. The 26 Ninth Circuit has “repeatedly recognized California’s contemporaneous objection rule as 27 ‘an adequate and independent state ground’ that forecloses [habeas] review.” Fauber v. 28 Davis, 43 F.4th 987, 1002 (9th Cir. 2022). 1 The California Court of Appeal squarely rejected Sosa’s due-process claim due to 2 his failure to contemporaneously object to the revised charges in his case. At his 3 preliminary hearing, Sosa “raised a due process concern about the length of the charging 4 periods,” and the trial court “acknowledged the due process implications.” Sosa, 2021 WL 5 220109, at *5. “When the hearing concluded, the court allowed the prosecution to amend 6 the timeframes in the complaint” and “Sosa was arraigned on an information filed two 7 weeks later.” Id. The Court of Appeal held that Sosa’s objection to the date ranges “should 8 have been pursued after the pleading changes that followed the preliminary hearing.” Id. 9 “Yet there were no objections or even concerns raised on these grounds either at the 10 conclusion of the preliminary hearing or in the intervening period of about a year before 11 the trial began.” Id. “Because [Sosa] did not take any steps to challenge the broad time 12 ranges on due process grounds at any point after the preliminary hearing,” the appellate 13 court held that his “attempt to revive this argument fails.” Id. In other words, the Court of 14 Appeal dismissed Sosa’s claim for failure to contemporaneously object—an independent 15 and adequate state ground precluding federal habeas review. Sosa makes several arguments 16 in an attempt to avoid this result. 17 1. Initial Forfeiture of the Claim 18 Sosa first maintains that he never “forfeit[ed] his claim.” (ECF 1, at 8.) He contends 19 that “to preserve an issue for appeal, it is sufficient for the objection to be raised in a manner 20 that alerts the trial court of the nature of the issue and affords the opposing counsel an 21 opportunity to respond,” or “even when there is no objection” the issue is preserved “if the 22 trial court rules on the issue.” (ECF 1, at 8; ECF 6, at 3.) Sosa says his claim is preserved 23 under this rule because “trial counsel clearly stated she had an issue with the date ranges” 24 and the court “understood” the objection to “implicate concerns of fair notice . . . [and] due 25 process.” (ECF 1, at 8; see also ECF 6, at 3.) And “even if trial counsel had said nothing 26 about date ranges . . . the trial court engaged in a somewhat lengthy discussion about how 27 the date ranges implicate due process concerns, and then made a ruling on the issue.” 28 (ECF 1, at 8; see also ECF 6, at 3.) Sosa also says that “nothing substantively changed after 1 the preliminary hearing regarding the date ranges,” and “[w]hile the prosecution may have 2 modified the length of the date ranges for existing counts, and added some new counts,” 3 his objection “remained apropos.” (ECF 6, at 3.) 4 Even if the Court agreed with Sosa on any of these points, “[f]ederal habeas courts 5 lack jurisdiction . . . to review state court applications of state procedural rules.” Poland v. 6 Stewart, 169 F.3d 573, 584 (9th Cir. 1999); see also Quintero v. Stewart, 121 F. App’x 7 203, 206 (9th Cir. 2005) (“While [petitioner] asserts that he did not waive his claim, as it 8 was raised before the trial court, this issue is beyond our reach.”). Since “it is not the 9 province” of this Court “to reexamine state-court determinations on state-law questions,” 10 the Court must reject Sosa’s argument that he did not forfeit his due-process claim. See 11 Estelle v. McGuire, 502 U.S. 62, 68–69 (1991). 12 To be clear, however, this Court does not agree with Sosa’s characterization of the 13 proceedings.

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