Wayne West v. Craig Koenig

CourtDistrict Court, C.D. California
DecidedMay 12, 2021
Docket2:21-cv-03727
StatusUnknown

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

Bluebook
Wayne West v. Craig Koenig, (C.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 WESTERN DIVISION 11 WAYNE WEST, ) Case No. 2:21-cv-03727-CJC-JDE ) 12 Petitioner, ) ) ORDER TO SHOW CAUSE ) 13 v. ) ) 14 CRAIG KOENIG, Warden, ) ) 15 Respondent. ) ) 16 ) 17 18 On April 19, 2021,1 Petitioner Wayne West (“Petitioner”) constructively 19 filed a Petition for Writ of Habeas Corpus by a Person in State Custody (Dkt. 20 1, “Petition” or “Pet.”) and a supporting Memorandum (Dkt. 2, “Mem.”), 21 raising a single ground for relief. The Court has screened the Petition 22 consistent with its authority under Rule 4 of the Rules Governing Section 2254 23 1 Under the “mailbox rule,” “a legal document is deemed filed on the date a 24 petitioner delivers it to the prison authorities for filing by mail.” Lott v. Mueller, 304 25 F.3d 918, 921 (9th Cir. 2002). In the absence of evidence to the contrary, courts have treated a petition as delivered to prison authorities on the date the petition is signed. 26 See Roberts v. Marshall, 627 F.3d 768, 770 n.1 (9th Cir. 2010). Here, for purposes of 27 this Order, the Court will afford Petitioner the benefit of the mailbox rule and deems the Petition to have been “filed” on April 19, 2021. 28 1 Cases in the United States District Courts (“Habeas Rules”) and finds that the 2 Petition appears to suffer from at least two defects. The Court thus orders 3 Petitioner to show cause why this action should not be dismissed. 4 I. 5 PROCEDURAL HISTORY 6 On October 4, 2016, following a plea of nolo contendere in the Los 7 Angeles County Superior Court, case number BA444069, Petitioner was 8 convicted and sentenced to a term of 21 years in prison for robbery with the 9 use of a weapon. Pet. at 2 (CM/ECF pagination is used herein for references 10 to the Petition); Mem. at 6. 11 Petitioner states he did not appeal his judgment of conviction to the 12 California Court of Appeal. Pet. at 3. However, California Court of Appeal 13 records reflect that, in an unpublished decision issued on October 18, 2017, the 14 state court of appeal affirmed Petitioner’s conviction and sentence following an 15 independent review of the record under People v. Wende, 25 Cal.3d 436 16 (1979) after Petitioner’s court appointed counsel filed an opening brief raising 17 no issues and Petitioner submitted a brief raising several issues.2 California 18 Courts, Appellate Case Information (“Appellate Case Information”) at 19 appellatecases.courtinfo.ca.gov, Second Appellate District, Division Four, 20 Case Nos. B298616, BA444069. 21 22 2 Pursuant to Rule 201 of the Federal Rules of Evidence, the Court takes judicial 23 notice of relevant state court records available electronically for the state courts. See 24 Holder v. Holder, 305 F.3d 854, 866 (9th Cir. 2002) (taking judicial notice of opinion and briefs filed in another proceeding); United States ex rel. Robinson Rancheria 25 Citizens Council v. Borneo, Inc., 971 F.2d 244, 248 (9th Cir. 1992) (courts “may take 26 notice of proceedings in other courts, both within and without the federal judicial system, if those proceedings have a direct relation to matters at issue” (citation 27 omitted)). 28 2 1 It does not appear Petitioner filed a timely Petition for Review of the 2 October 18, 2017 opinion affirming his conviction and sentence. See Pet. at 4 3 (reflecting that Petitioner did not answer the question whether he filed a 4 Petition for Review); Dkt. 2 at 6 (December 23, 2019 Order by the California 5 Court of Appeal reflecting “the matter in trial number BA444069 is final and 6 has been since 2017). 7 Barring a timely filing of a Petition for Review of the California Court of 8 Appeals decision affirming the judgment, Petitioner’s judgment became final 9 on November 27, 2017, 40 days after the order affirming his judgment of 10 conviction was filed. See Cal. R. Ct. 8.366(b)(1) (providing that court of appeal 11 decision becomes final 30 days after filing); Cal. R. Ct. 8.500(e)(1) (providing 12 that a Petition for Review must be served and filed within 10 days of a court of 13 appeal decision becoming final). Petitioner asserts he did not file any habeas 14 petitions in state court with respect to his judgment of conviction. See Pet. at 4. 15 II. 16 PETITIONER’S CLAIM 17 The sole claim raised in the Petition is Petitioner’s assertion that the state 18 courts denied his March 19, 2019 motion for modification of his sentence 19 under California Senate Bill 1393 (“SB 1393”), which, according to Petitioner, 20 became effective on January 1, 2019, and gave California trial courts the 21 discretion to dismiss sentencing enhancements based upon prior convictions 22 for serious felonies. See Pet. at 6; Mem. at 1-4. 23 II. 24 DISCUSSION 25 Under Rule 4 of the Habeas Rules, the Court must review the Petition 26 and, if it plainly appears from the Petition and any attached exhibits that the 27 Petitioner is not entitled to relief, the Court must dismiss the Petition. Here, 28 3 1 the Petition appears subject to dismissal for two reasons: (1) the sole claim 2 raised in the Petition appears to be non-cognizable on federal habeas review; 3 and (2) the Petition appears to be untimely. The Petition therefore appears to 4 be subject to dismissal under Rule 4. 5 A. The Petition’s Sole Claim Appears to Be Non-Cognizable 6 The Petition appears subject to dismissal as non-cognizable as the only 7 underlying claim is based solely on an alleged violation of state law. “In 8 conducting habeas review, a federal court is limited to deciding whether a 9 conviction violated the Constitution, laws, or treaties of the United States.” 10 Estelle v. McGuire, 502 U.S. 62, 68 (1991); Smith v. Phillips, 455 U.S. 209, 11 221 (1982) (“A federally issued writ of habeas corpus, of course, reaches only 12 convictions obtained in violation of some provision of the United States 13 Constitution.”). Federal habeas relief is not available for errors of state law. 14 See 28 U.S.C. § 2254(a); McGuire, 502 U.S. at 67-68. 15 Petitioner claims he did not receive a resentencing in violation of a new 16 state law. Petitioner cites only state law in support of his claim and identifies 17 no federal constitutional violation. Further, a claim that a failure to resentence 18 a petitioner under SB 1393 “does not state a claim for federal habeas relief.” 19 Bush v. Davis, 2020 WL 7043882, at *2 (N.D. Cal. Dec. 1, 2020); see also 20 Burchett v. Martel, 2020 WL 1847131, at *2, report and recommendation 21 adopted by 2020 WL 1820518 (C.D. Cal. Apr. 10, 2020) (petitioner's 22 allegations regarding S.B. 1393 involve an alleged misapplication of state law 23 and “[a]s such, they fail to state a cognizable federal claim.”); O'Neil v. 24 Burton, 2019 WL 6915690, at *2, report and recommendation adopted by 25 2020 WL 363352 (E.D. Cal. Jan. 22, 2020) (“petitioner's effort to obtain the 26 benefit of California Senate Bill 1393 implicates state law only,” and therefore 27 federal habeas relief is unavailable); McKinney v. Pfeiffer, 2019 WL 5686334, 28 4 1 at *3, report and recommendation adopted by 2019 WL 5683471 (C.D. Cal 2 Oct.

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Bluebook (online)
Wayne West v. Craig Koenig, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wayne-west-v-craig-koenig-cacd-2021.