Schaffer v. Clay

Background

Craig Raymond Schaffer, identified in the order as a state prisoner proceeding without a lawyer, filed a petition for federal habeas relief under 28 U.S.C. § 2254. He asked the court to dismiss his state criminal charges and release him. He argued that his commitment became unlawful after a finding that he was incompetent to stand trial, that the incompetency finding was wrong, and that his arrest involved entrapment, swatting, illegal surveillance, stalking by an unidentified person, and “electronic warfare.”

Schaffer also alleged that he was being forcibly medicated and required to undergo “conversion therapy” related to his transgender identity. He said the state hospital had illegally changed his sex back to female. In addition, he filed a motion to dismiss the state charges and an application to proceed without paying the filing fee.

Release and State-Court Proceedings

The court determined that Schaffer’s state criminal case was still ongoing. Applying the rule from Younger v. Harris, the court said federal courts generally must not interfere with ongoing state criminal proceedings. The court found that Schaffer had not identified the extraordinary circumstances that could permit such interference.

The court also said that federal habeas review could not provide release while the state criminal trial and state appeals remained unresolved. It stated that Schaffer could seek federal habeas relief after the state criminal trial concluded and he unsuccessfully appealed to the California First District Court of Appeal and the California Supreme Court.

The court dismissed Schaffer’s claims requesting release and dismissal of the criminal charges without prejudice. It also denied the motion requesting release and denied the motion to dismiss the state charges. The court’s use of “without prejudice” means the dismissal of those claims did not bar Schaffer from pursuing a new federal habeas action after the state proceedings concluded.

Medical and Confinement Claims

The court ruled that the medical claims were not barred by the rule against interfering with ongoing state proceedings because they concerned confinement conditions rather than a request for release. However, the court held that those claims could not proceed in a habeas action. Because a successful challenge to those conditions would not necessarily shorten Schaffer’s sentence, the court said the claims should be brought, if at all, under 42 U.S.C. § 1983, the federal civil-rights statute used for certain claims against state officials.

The court did not decide whether Schaffer’s medical claims were legally valid. Instead, it ordered him to state in writing by May 30, 2025, whether he wanted the court to convert the habeas action into a § 1983 civil-rights action or dismiss the remainder of the petition. He could also respond by voluntarily dismissing the action. The court warned that failing to respond would result in dismissal without prejudice.

Filing Fee and Further Procedure

The court denied Schaffer’s application to proceed without paying the filing fee because the required initial assessment would exceed the filing fee for a habeas petition. The order explained that the filing fee for a habeas petition is five dollars, while a civil-rights case carries a stated fee of $405, or $350 if pauper status is granted, with payment collected from a prisoner’s trust-account income under the Prisoner Litigation Reform Act.

Disposition

Judge P. Casey Pitt dismissed the release and state-case-interference claims without prejudice, denied the motion to dismiss the charges, denied the motion requesting release, and denied the application to proceed without paying the filing fee. The court required Schaffer to choose whether to convert the case to a civil-rights action or dismiss the remaining petition. The order did not reach the merits of the medical claims.