Chavez v. Smith
- Laurel Beeler
- 3:25-cv-04111
- U.S. District Court · Northern District of California
- 1
In Chavez v. Smith, Judge Beeler dismissed Chavez’s federal habeas petition because it raised only state-law issues and denied a certificate of appealability.
The ruling directly affected Enrique G. Chavez’s federal petition challenging restitution. The court granted his request to proceed without paying the filing fee but dismissed the petition, denied a certificate of appealability, entered judgment for Stephee Smith, and closed the case.
What happened
Enrique G. Chavez, a state prisoner representing himself, filed a federal petition challenging restitution imposed as part of his sentence of life without parole. He argued that the restitution violated California law.
The court explained that a claim based only on state law cannot be considered in a federal petition challenging imprisonment. The court also said the claim appeared to be filed too late and had not been presented first to California courts.
In Enrique G. Chavez v. Stephee Smith, Judge Laurel Beeler dismissed the petition, granted Chavez’s request to proceed without paying the filing fee, denied a certificate of appealability, entered judgment for Smith, and closed the case.
The detailed version
- Chavez v. Smith · No. 3:25-cv-04111
- Laurel Beeler
- Sept. 29, 2025
Background
Enrique G. Chavez, a state prisoner proceeding without a lawyer, filed a petition under 28 U.S.C. § 2254, the federal statute allowing a state prisoner to challenge custody in federal court. Chavez raised one claim: that restitution was imposed in violation of California law because he was sentenced to life without parole.
Chavez also filed a motion for permission to proceed without paying the filing fee. The court granted that motion.
Court’s Analysis
The court held that a claim based only on state law is not a claim that can be considered in a federal habeas proceeding. The court also stated that Chavez’s claim appeared to be untimely and not exhausted in the California courts. Exhaustion generally requires presenting the claim to the state courts before seeking federal habeas relief, but the order did not provide further analysis of those issues.
Disposition
The court entered an order of dismissal. It denied a certificate of appealability, finding that this was not a case in which reasonable judges would debate whether the court’s assessment of the constitutional claims was wrong. The clerk was directed to enter judgment for the respondent and close the file. The order terminated Docket No. 6, Chavez’s filing-fee motion, which the court had granted.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.