Williams v. Borla

Background

Cameron Williams, an inmate at the Correctional Training Facility, filed a pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254. A federal habeas petition asks a federal court to review whether a person is held in violation of federal law. The court reviewed the petition under 28 U.S.C. § 2243 and Rule 4 of the Rules Governing Section 2254 Cases.

Williams pleaded guilty to voluntary manslaughter, being a felon in possession of a firearm, and the use of a firearm. He was sentenced on December 9, 2020, to 21 years and 8 months in prison. He did not appeal. He filed three state habeas petitions in the Superior Court of California for the County of San Francisco and pursued the third to the California Supreme Court, which denied it on March 12, 2024. He filed the federal petition on April 22, 2024.

Claims and analysis

The petition listed claims concerning denial of the opportunity to argue self-defense, perjured testimony or mitigating evidence, prosecutorial misconduct including an alleged violation involving favorable evidence, and relief under a newly enacted state law. Williams also alleged ineffective assistance of counsel, including failures to investigate and other alleged failures occurring at trial.

The court explained that a guilty plea generally prevents a person from later raising independent claims about constitutional violations that occurred before the plea. After a guilty plea, the remaining federal habeas challenges generally concern whether the plea was voluntary and informed or whether counsel adequately advised the person about the plea. The court also recognized narrow exceptions for challenging the state’s power to bring the person into court and for double jeopardy claims.

The court concluded that Williams did not raise claims falling within those exceptions. Although he alleged ineffective assistance of counsel, he did not allege that counsel was ineffective specifically in advising him about the guilty plea. The court also held that his request for relief under a newly enacted state law was not a claim that could be decided in a federal habeas proceeding, because federal habeas relief is unavailable for violations of state law or alleged errors in applying state law.

Disposition

Judge P. Casey Pitts dismissed the petition with leave to amend. Williams may file a first amended petition within 35 days from the date the order was filed. Any amended petition must use the caption and civil case number specified in the order and state “FIRST AMENDED PETITION” on its first page. The court stated that an amended pleading replaces the original pleading.

The court further stated that failure to file an amended petition within 35 days and in accordance with the order will result in a finding that further amendment would be futile. It also warned that failure to prosecute the case or comply with court orders could result in dismissal under Federal Rule of Civil Procedure 41(b).