(HC) Sanford v. Koenig
2:19-cv-01995
E.D. Cal.Dec 17, 2021Background
- Petitioner Adam Sanford, a California state prisoner, was convicted on March 23, 2016 of multiple offenses the state treats as violent felonies, which make him ineligible for "non-violent" custody credits.
- Sanford argues that federal law standards (citing United States v. Garcia-Lopez) define what counts as a crime of violence, and that those federal standards should govern his classification so he can receive non-violent offender credits.
- Sanford filed a § 2254 habeas petition in federal court; Respondent answered and lodged state-court records; Sanford did not file a traverse.
- The El Dorado County Superior Court denied relief, noting federal sentencing law is irrelevant to state sentencing; the California Court of Appeal and California Supreme Court summarily denied relief.
- The magistrate judge recommended dismissal of the § 2254 petition for lack of federal habeas jurisdiction because the claim is a state-law classification dispute, not a federal constitutional violation, and does not allege a miscarriage of justice or due-process infection of the entire proceeding.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal sentencing law (federal "crime of violence" standard) governs California's classification for custody-credit eligibility | Sanford: federal standard should apply and his offenses are not violent under that standard, so he should get non-violent credits | Respondent/State: Federal sentencing law is not relevant to state convictions or state credit determinations | Court: Petition dismissed for lack of jurisdiction; federal standard not controlling for state classification |
| Whether the claim is cognizable on federal habeas (i.e., implicates federal constitutional error or miscarriage of justice) | Sanford: seeks relief based on federal decisions cited (implied constitutional effect) | Respondent/State: Claim is a state-law error; no showing of a due-process violation or complete miscarriage of justice | Court: Claim is a state-law issue not cognizable on § 2254 and does not show the necessary miscarriage of justice; dismissal recommended |
Key Cases Cited
- United States v. Garcia-Lopez, 903 F.3d 887 (9th Cir. 2018) (federal sentencing interpretation of California robbery statute cited by petitioner)
- Middleton v. Cupp, 768 F.2d 1083 (9th Cir. 1985) (habeas relief limited to transgressions of federal law binding on state courts)
- Gutierrez v. Griggs, 695 F.2d 1195 (9th Cir. 1983) (habeas not available for state-law errors)
- Milton v. Wainwright, 407 U.S. 371 (1972) (habeas cannot be used to retry state-law issues de novo)
- Hill v. United States, 368 U.S. 424 (1962) (habeas relief requires error causing a complete miscarriage of justice)
- Hines v. Enomoto, 658 F.2d 667 (9th Cir. 1981) (non-constitutional errors may warrant habeas only if they so infect the trial as to violate due process)
- Martinez v. Ylst, 951 F.2d 1153 (9th Cir. 1991) (procedural note on waiver for failure to object)