Steven L. Harris v. Jennifer Tyvand, Warden

District Court, D. Idaho·Decided August 14, 2026·No. 1:24-cv-00433·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

STEVEN L. HARRIS,

Petitioner, Case No. 1:24-cv-00433-REP

vs. MEMORANDUM DECISION AND ORDER JENNIFER TYVAND, Warden,

Respondent.

Pending before the Court in this habeas corpus action are Petitioner Steven Harris’s two Motions for Summary Judgment (Dkts. 42, 51), and Respondent Jennifer Tyvand’s Motion for Summary Dismissal (Dkt. 48). Petitioner has also filed three motions requesting court rulings on the outstanding motions. Dkts. 52, 54, 56. All named parties have consented to the jurisdiction of a United States Magistrate Judge to enter final orders in this case. Dkt. 7. See 28 U.S.C. § 636(c) and Fed. R. Civ. P. 73. Having reviewed the state court record and the federal court record, the Court enters the following Order dismissing the Petition for Writ of Habeas Corpus with prejudice.

MEMORANDUM DECISION AND ORDER - 1 REVIEW OF MOTION FOR SUMMARY DISMISSAL: CLAIM 1 IS NONCOGNIZABLE

Claim 1 is that Petitioner’s Fourth Amendment rights were violated because officers stopped his car “for no reason” and without “probable cause.” Dkt. 3 at 6. Respondent argues that Claim 1 is noncognizable. 1. Standard of Law Fourth Amendment claims are treated in a unique manner in habeas corpus actions. When a State has provided a defendant with an opportunity for full and fair litigation of a Fourth Amendment claim, it may not be relitigated by a federal district court in a habeas corpus action, “regardless of its view of the correctness of the state decision.” Mack v. Cupp, 564 F.2d 898, 901 (9th Cir. 1977) (relying on Stone v. Powell,

428 U.S. 465, 481–82 (1976) (Fourth Amendment issues are not cognizable on federal habeas review); Caldwell v. Cupp, 781 F.2d 714, 715 (9th Cir. 1986). Thus, the threshold issue for a Fourth Amendment claim is whether petitioner had an initial opportunity for a fair hearing in state court. See Caldwell, 781 F.2d at 715. The narrow question is not whether he did in fact have a hearing “or even whether the claim

was correctly decided.” Ortiz-Sandoval v. Gomez, 81 F.3d 891, 899 (9th Cir. 1996); see also Gordon v. Duran, 895 F.2d 610, 613-14 (9th Cir. 1990). The petitioner bears the burden of establishing that the state courts did not consider the Fourth Amendment claim fully and fairly. Mack, 564 F.2d at 901.

MEMORANDUM DECISION AND ORDER - 2 Powell does not specify a particular test for determining whether a state provided a defendant with an opportunity for full and fair litigation of a Fourth Amendment claim. To aid in determination of this question, federal district courts in the Ninth Circuit review

the transcripts and briefing from the state trial and appellate courts. See Terrovona v. Kincheloe, 912 F.2d 1176, 1178-1179 (9th Cir. 1990) (citing Abell v. Raines, 640 F.2d 1085, 1088 (9th Cir. 1981)), cert. denied, 499 U.S. 979 (1991). 2. Relevant Facts Petitioner was driving a vehicle without a rear license plate, and the rear brake and

left turn signal were not operating. State’s Lodging A-1 at 26. Officer Matthew Gonzales stopped the vehicle and approached Petitioner, who did not possess a current driver’s license, had slurred speech, impaired memory, and glassy or bloodshot eyes. Id. Gonzales could smell alcohol and Petitioner admitted he had been drinking. Id. Gonzles administered the Horizontal Gaze Nystagmus test and “observed 6 clues

of impairment.” Id. After consenting to giving a breath sample, Petitioner conceded he would “flunk” because “he had drunk several beers throughout the day.” Id. His resulting BrAC was .296/.288. Id. Harris was arrested for excessive driving under the influence (“DUI”). Id. Petitioner waived his preliminary hearing, which would have required the State to

provide evidence supporting probable cause. State’s Lodging A-1 at 34-37. An Information was filed, charging Harris with excessive DUI, a felony under Idaho Code §

MEMORANDUM DECISION AND ORDER - 3 18 8004C(2). Id. at 38-39. The State later filed an Amended Information asserting Petitioner was a persistent violator of the law. Id. at 58-59. The court entered a scheduling order specifically addressing how to file a motion

to suppress evidence. Id. at 46. Petitioner wrote a letter to the judge in response, stating that he did not have documentation of his arrest (audio, video, or documentary evidence) and he needed help obtaining that evidence. Id. at 51. The court sent Petitioner a response letter notifying him personally that the judge was unable to review ex parte communications and that Petitioner should direct his questions to his public defender,

Sean Wynn. Id. at 54. Petitioner complained about his counsel in a pretrial conference, and the court made findings and left the representation in place. Id. at 55. With the aid of counsel, Petitioner entered into a plea agreement to plead guilty to excessive DUI in exchange for the State dismissing the persistent violator sentencing enhancement and agreeing to recommend a unified ten-year sentence with the first five

years fixed; the agreement included waiving his right to file a motion to reconsider his sentence and his right to appeal unless the trial court exceeded the State’s sentencing recommendation. Id. at 75-76. Petitioner completed and signed a Guilty Plea Advisory form that advised him of the rights he was forfeiting, including the right to confront the witnesses against him,

which would include his right to cross-examine the arresting officer. Id. at 65-74.

MEMORANDUM DECISION AND ORDER - 4 The form advised Petitioner: Your attorney can obtain various items from the prosecutor relating to your case. This may include police reports, witness statements, tape recordings, photographs, reports of scientific testing, etc. This is called “discovery." Have you had the opportunity to review the discovery provided by your attorney?

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