Tolentino v. Andes

CourtDistrict Court, S.D. California
DecidedJuly 8, 2025
Docket3:25-cv-01687
StatusUnknown

This text of Tolentino v. Andes (Tolentino v. Andes) 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
Tolentino v. Andes, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 EDUARDO TOLENTINO, Case No.: 25-cv-1687-CAB-MMP

12 Petitioner, ORDER: 13 v. (1) GRANTING MOTION TO PROCEED 14 CHANCE ANDES, et al., IN FORMA PAUPERIS AND 15 Respondents. (2) NOTIFYING PETITIONER OF 16 OPTIONS TO AVOID DISMISSAL OF 17 PETITION

18 [Doc. No. 2] 19 20 Petitioner, a state prisoner proceeding pro se, has filed a Petition for Writ of Habeas 21 Corpus pursuant to 28 U.S.C. § 2254. [Doc. No. 1.] Petitioner has also filed a motion for 22 leave to proceed in forma pauperis and has submitted his trust account statement. [Doc. 23 Nos. 2–3.] For the reasons discussed, the Court GRANTS the motion to proceed in forma 24 pauperis and NOTIFIES Petitioner of his options to avoid a future dismissal of the instant 25 habeas action. 26 I. REQUEST TO PROCEED IN FORMA PAUPERIS 27 Petitioner has $0.05 on account at the California correctional institution in which he 28 is presently confined, [see Doc. No. 3 at 2], and cannot afford the $5.00 filing fee. 1 Accordingly, the Court GRANTS Petitioner’s motion to proceed in forma pauperis and 2 allows him to prosecute the above-referenced action without being required to prepay fees 3 or costs and without being required to post security. The Clerk of Court will file the 4 Petition without prepayment of the filing fee. 5 II. FAILURE TO EXHAUST STATE COURT REMEDIES 6 Upon review, it does not appear state court remedies have been exhausted as to any 7 of the four enumerated claims in the Petition. Habeas petitioners who wish to challenge 8 either their state court conviction or the length of their confinement in state prison must 9 first exhaust state judicial remedies. See 28 U.S.C. § 2254(b), (c); Granberry v. Greer, 481 10 U.S. 129, 133-34 (1987); see also Picard v. Connor, 404 U.S. 270, 275 (1971) (“[A] state 11 prisoner must normally exhaust available state judicial remedies before a federal court will 12 entertain his petition for habeas corpus.”) “A petitioner has satisfied the exhaustion 13 requirement if: (1) he has ‘fairly presented’ his federal claim to the highest state court with 14 jurisdiction to consider it,” which in this case is the California Supreme Court, “or (2) he 15 demonstrates that no state remedy remains available.” Johnson v. Zenon, 88 F.3d 828, 829 16 (9th Cir. 1996) (citations omitted); see also O’Sullivan v. Boerckel, 526 U.S. 838, 845 17 (1999) (“[S]tate prisoners must give the state courts one full opportunity to resolve any 18 constitutional issues by invoking one complete round of the State’s established appellate 19 review process.”) 20 Additionally, the claims presented in the federal courts must be the same as those 21 exhausted in state court and must also allege, in state court, how one or more of his federal 22 rights have been violated. See Picard, 404 U.S. at 276 (“Only if the state courts have had 23 the first opportunity to hear the claim sought to be vindicated in a federal habeas proceeding 24 does it make sense to speak of the exhaustion of state remedies. Accordingly, we have 25 required a state prisoner to present the state courts with the same claim he urges upon the 26 federal courts.”); see also Duncan v. Henry, 513 U.S. 364, 365-66 (1995) (“If state courts 27 are to be given the opportunity to correct alleged violations of prisoners’ federal rights, 28 they must surely be alerted to the fact that the prisoners are asserting claims under the 1 United States Constitution. If a habeas petitioner wishes to claim that an evidentiary ruling 2 at a state court trial denied him the due process of law guaranteed by the Fourteenth 3 Amendment, he must say so, not only in federal court, but in state court.”) 4 Of the four claims presented in his federal Petition, Petitioner indicates he has not 5 raised any of these claims in the California Supreme Court. [See Doc. No. 1 at 6-14.] 6 Petitioner indicates that he has filed the instant federal Petition “as a safety petition because 7 I am exhausting state remedies and I am reasonably confused on applicable law regarding 8 the federal statute of limitations for bringing Habeas Corpus Petitions,” as well as states 9 that he filed a habeas corpus petition in the California Court of Appeal which was recently 10 denied and that he intends to seek review in the California Supreme Court. [Id. at 4-5; see 11 also Doc. No. 1-2.] 12 In Rose v. Lundy, 455 U.S. 509 (1982), the United States Supreme Court held that a 13 petition which constains unexhausted claims is subject to dismissal because it violates the 14 “total exhaustion rule” required in habeas petitions brought pursuant to § 2254, but that a 15 petitioner must be permitted an opportunity to cure that defect prior to dismissal. Id. at 16 514-20. Because the one-year statute of limitations imposed on section 2254 habeas 17 petitions after Lundy was decided created a risk of a claim dismissed under Lundy 18 becoming time-barred, the Supreme Court subsequently approved of a procedure by which 19 a federal Petition could be stayed while a petitioner returned to state court to exhaust. See 20 Rhines v. Weber, 544 U.S. 269, 277–78 (2005); see also Mena v. Long, 813 F.3d 907, 912 21 (9th Cir. 2016) (“[A] district court has the discretion to stay and hold in abeyance fully 22 unexhausted petitions under the circumstances set forth in Rhines.”) The Supreme Court 23 has instructed “stay and abeyance should be available only in limited circumstances” and 24 was appropriate where: (1) “there was good cause for the petitioner’s failure to exhaust his 25 claims first in state court,” (2) the “unexhausted claims are potentially meritorious” and 26 (3) “there is no indication that the petitioner engaged in intentionally dilatory litigation 27 tactics.” Rhines, 544 U.S. at 277–78. 28 /// 1 The Court now notifies Petitioner of his options to avoid a future dismissal for 2 presenting a petition with only unexhausted claims, with a deadline set forth below. 3 I. First Option: Demonstrate Exhaustion 4 Petitioner may file papers in which he alleges he has exhausted the claim(s) in the 5 Petition. If Petitioner chooses this option, these papers are due no later than September 8, 6 2025. 7 II. Second Option: Voluntarily Dismiss the Petition 8 Petitioner may move to voluntarily dismiss his entire federal petition and return to 9 state court to exhaust his unexhausted claim(s). Petitioner may then file a new federal 10 petition containing only exhausted claims. 11 Petitioner is cautioned that any new federal petition must be filed before expiration 12 of the one-year statute of limitations. Ordinarily, a petitioner has one year from when his 13 conviction became final to file his federal petition, unless he can show that statutory or 14 equitable “tolling” applies. Duncan v. Walker, 533 U.S. 167, 176 (2001); 28 U.S.C. 15 § 2244(d).1 The statute of limitations does not run while a properly filed state habeas 16

17 1 28 U.S.C. § 2244

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Related

Fletcher v. Peck
10 U.S. 87 (Supreme Court, 1810)
Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Artuz v. Bennett
531 U.S. 4 (Supreme Court, 2000)
Rhines v. Weber
544 U.S. 269 (Supreme Court, 2005)
Duhaime v. John Hancock Mutual Life Insurance
183 F.3d 1 (First Circuit, 1999)
Samuel Quinton Bonner v. Tom Carey, Warden
425 F.3d 1145 (Ninth Circuit, 2005)
Samuel Quinton Bonner v. Tom Carey, Warden
439 F.3d 993 (Ninth Circuit, 2006)
Duncan v. Henry
513 U.S. 364 (Supreme Court, 1995)
Armando Mena v. David Long
813 F.3d 907 (Ninth Circuit, 2016)

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Tolentino v. Andes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tolentino-v-andes-casd-2025.