Collier v. Hill, 4:24-cv-07096

Joe Robert Collier, incarcerated at Richard J. Donovan Correctional Facility, challenged his 2013 Santa Clara County sentence for first-degree burglary via a federal habeas petition under 28 U.S.C. § 2254.
Collier's sentence included enhancements based on prior serious felony convictions from 1991 and 1997, both resulting from plea bargains.
After initial direct appeal and multiple state habeas petitions were denied, Collier filed a prior federal habeas petition challenging ten claims; only one (regarding pre-trial identification) went to the merits and was denied.
In this action, Collier argued that recent changes to California law (Cal. Penal Code § 1016.8 via Assembly Bill 1618) rendered his prior plea-based convictions invalid, and thus his sentence illegal.
The district court permitted Collier to proceed in forma pauperis, but reviewed the merits of his claim under federal habeas standards.

Issue	Collier's Argument	Hill's Argument	Held
Whether Collier can challenge his current sentence via federal habeas by contesting the validity of prior convictions used for sentence enhancements?	Collier argued that Cal. Penal Code § 1016.8 applies retroactively to his prior plea bargains, invalidating two prior convictions and thus the enhanced sentence.	Hill responded that federal law bars this type of habeas challenge unless there's a Sixth Amendment violation or other narrow exceptions, none of which apply.	Court held Lackawanna bars Collier's challenge; no exception applies.
Does Cal. Penal Code § 1016.8 apply retroactively to Collier's prior convictions?	Collier asserted § 1016.8 is retroactive and voids his prior plea-based convictions.	Hill maintained § 1016.8 applies only to non-final cases as of Jan. 1, 2020, not to Collier's final convictions.	Court agreed with Hill; § 1016.8 inapplicable to Collier.
Is Collier entitled to a certificate of appealability?	Collier sought permission to appeal, implying reasonable debate exists.	Hill argued, and the court found, that no substantial constitutional question exists.	Court denied certificate.

Rose v. Hodges, 423 U.S. 19 (1975) (explains federal court habeas jurisdiction for state inmates)
Lackawanna County Dist. Attorney v. Coss, 532 U.S. 394 (2001) (generally bars federal habeas challenges to prior convictions used to enhance current sentence, subject to narrow exception)
Slack v. McDaniel, 529 U.S. 473 (2000) (sets standard for issuing a certificate of appealability)