Roberts v. Hartley
640 F.3d 1042
9th Cir.2011Background
- Roberts was convicted of second-degree murder and sentenced to life with the possibility of parole.
- In June 2006, the Board denied Roberts parole after considering the evidence against him.
- Roberts sought collateral relief in state court, which upheld the Board's decision under California's some-evidence standard.
- Roberts petitioned for federal habeas corpus; the district court granted relief, finding misapplication of California law by state courts.
- The Ninth Circuit later noted Cooke v. Solis, which held the federal due process inquiry is twofold and limited to minimal procedural protections, and reversed accordingly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state court's misapplication of California's some-evidence standard violated due process | Roberts: misapplication violated due process | Hartley: Cooke governs; misapplication alone does not raise federal due process | No due process violation; procedures were sufficient under Greenholtz and Cooke |
| Whether misapplication of state law provides a basis for federal habeas relief | Roberts relies on misapplication to obtain relief | Hartley: state-law misapplication cannot support federal habeas relief | Cooke prohibits relief for state-law errors; relief reversed |
| Whether Cooke overrules prior Ninth Circuit precedent on review of some-evidence determinations | Roberts contends prior cases require federal review of state factual findings | Hartley: Cooke controls and limits review to due process procedures | Cooke controls; former misapplication precedent overruled for habeas claims |
Key Cases Cited
- Cooke v. Solis, 606 F.3d 1206 (9th Cir. 2010) (held parole denial involves minimal due process requirements and that state-court misapplication does not guarantee federal relief)
- Hayward v. Marshall, 603 F.3d 546 (9th Cir. 2010) (overruled line of cases requiring due process right to parole via some evidence)
- Pearson v. Muntz, 625 F.3d 539 (9th Cir. 2010) (parole due process standards clarified in light of Hayward)
- Pirtle v. California Bd. of Prison Terms, 611 F.3d 1015 (9th Cir. 2010) (parole procedural framework discussed in circuit)
- Irons v. Carey, 505 F.3d 846 (9th Cir. 2007) (distinction between good time and parole in due process analysis)
- In re Rosenkrantz, 29 Cal.4th 616 (Cal. 2002) (state standard of 'some evidence' for parole review)
- Bd. of Pardons v. Allen, 482 U.S. 369 (1987) (establishes liberty interest in parole under state scheme)
- Greenholtz v. Inmates of Neb. Penal & Corr. Complex, 442 U.S. 1 (1980) (parole procedures must provide opportunity to be heard and reasons for denial)
- Superintendent v. Hill, 472 U.S. 445 (1985) (due process considerations for good-time credits (distinguished from parole))
- Cooke v. Solis, 131 S. Ct. 859 (2011) (Supreme Court decision applying two-step due process analysis to parole decisions; directive that CA courts assess proper procedures)