Ivan Rueda v. Bryan Birkholz
2:25-cv-04110
| C.D. Cal. | Jun 27, 2025Background
- Ivan Rueda, a federal inmate at FCI Lompoc II, filed a habeas corpus petition under 28 U.S.C. § 2241.
- The initial petition was dismissed with leave to amend; Rueda filed a First Amended Petition (FAP) alleging lack of assistance for his blindness at the facility.
- Rueda requests either assignment of an inmate companion or transfer to a facility with such a program, citing ongoing injuries and "medical indifference."
- The Court found the FAP corrects a previous defect but now faces a threshold jurisdictional issue: whether the matter is properly brought as a habeas action or as a civil rights complaint.
- The Court noted that Rueda’s claims pertain to conditions of confinement (accommodations for disability), not the legality, fact, or duration of confinement.
- Petitioner was ordered to clarify or amend his claims by July 28, 2025 or face possible dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claims for disability accommodations in prison are cognizable in habeas | Rueda: Lack of mobility assistance violates his rights, seeks court-ordered accommodations | (No defendant argument presented; not yet responded) | Claims challenging conditions, not validity or duration of custody, are not cognizable under habeas |
| Whether the petition should be converted to a civil rights complaint | Rueda wants relief via court order for accommodations | N/A | Conversion not appropriate unless fee, consent, and form issues resolved |
| Whether summary dismissal is appropriate absent response | Rueda may argue for court jurisdiction or amend petition | N/A | Dismissal will follow unless petitioner responds or amends as directed |
| Whether a habeas petition can generate relief for ADA or "medical indifference" claims | Rueda describes medical indifference as habeas-eligible | N/A | Such claims must be brought as civil rights, not habeas, actions |
Key Cases Cited
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (Habeas corpus is for challenges to legality of custody, not conditions of confinement)
- Tucker v. Carlson, 925 F.2d 330 (9th Cir. 1991) (Habeas under 2241 only for fact or duration of custody, not conditions)
- Crawford v. Bell, 599 F.2d 890 (9th Cir. 1979) (Section 2241 is not for challenges to prison conditions)
- Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971) (Civil rights claim for federal prisoners)