Watson v. People of Contra Costa County Superior Court

Background

Michael Anthony Watson, a prisoner proceeding without a lawyer, filed a petition and attachments concerning his 2013 conviction and sentence and a habeas petition he said he had filed in Contra Costa County Superior Court. The filing referenced a writ of mandate, a federal habeas petition, a civil-rights action, coram nobis, arbitration, federal and state statutes, and various constitutional provisions. The court found the documents generally unclear and difficult to follow.

The filing appeared to seek modification or vacatur of Watson’s conviction, resentencing, and an order requiring the Contra Costa County Superior Court to address his state habeas petition. The court also noted that the filing did not include the referenced habeas petition or “Exhibit A.”

Screening and Reasons for Dismissal

Because Watson was a prisoner seeking relief from a governmental entity, the court screened the action under 28 U.S.C. § 1915A. That statute requires the court to identify claims that are legally viable and dismiss claims that are frivolous, fail to state a claim, or seek money from an immune defendant.

The court identified several problems. First, it was unclear whether Watson intended to file in federal court or state court. To establish federal-question jurisdiction over a suit against a California state agency, the court explained, the filing had to allege a violation of federal law or the federal Constitution.

Second, it was unclear whether Watson sought a writ of mandamus, a federal habeas petition, or another type of action. To the extent he sought an order directing the state court to take action, the court held that federal district courts lack power to issue mandamus orders controlling state courts, state judicial officers, or other state officials. The court described such a mandamus action as frivolous as a matter of law.

To the extent Watson sought federal habeas relief challenging his 2013 conviction and sentence, the court stated that the petition was likely barred as a “second or successive” petition because Watson had previously challenged that conviction and sentence in a prior related proceeding, Case No. 17-cv-0100-BLF. The court explained that Watson could not bring a later challenge in the district court unless he first obtained authorization from the Ninth Circuit. The court also stated that it could not instruct the state court how to handle a pending state habeas petition because principles requiring federal courts to respect ongoing state proceedings barred that interference absent extraordinary circumstances.

Motions

The court denied the motion in ECF No. 2 seeking appointed counsel and other relief. It held that the Sixth Amendment right to counsel applies to an accused person undergoing criminal prosecution, not to state collateral proceedings or federal habeas proceedings. The court also concluded that this action was not an arbitration proceeding to which California arbitration-counsel rules applied.

The court denied the request in ECF No. 3 concerning an evidentiary standard, the Delay Reduction Act, and arbitration. It stated that the appropriate legal and evidentiary standards depended on the type of action Watson was bringing, that the California law cited did not govern the federal court, and that any request to refer the matter to an early settlement program was premature.

The court denied the request in ECF No. 4 concerning recall of Watson’s sentence, resentencing, and review of his state-court conviction and sentence. The court again referred to the likely restrictions on a later habeas challenge and explained that federal courts have limited authority over state courts.

Disposition

The court denied the requests contained in ECF Nos. 2, 3, and 4. It dismissed the action with leave to amend. Watson was given 28 days from the date of the order to file an amended complaint or petition addressing the identified deficiencies. The court stated that an amended filing would replace the prior filing and must include all claims and defendants or respondents Watson wished to pursue. Failure to file an adequate amended filing within the permitted time would result in dismissal without further notice. The order terminated ECF Nos. 2, 3, and 4.