Lawson v. Cates

Background

William D. Lawson Jr., identified as a California prisoner proceeding without an attorney, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254. The petition challenges the validity of his conviction in Butte County Superior Court.

Venue and transfer

Under 28 U.S.C. § 2241(d), a state prisoner challenging a state-court judgment may file a habeas petition in either the federal district where the prisoner is confined or the federal district where the prisoner was convicted. Those districts have concurrent jurisdiction, but the district where the petition was filed may transfer it to the other district in the interest of justice.

The court stated that federal courts in California traditionally hear petitions challenging a conviction or sentence in the federal district where the conviction occurred. It also cited the Northern District of California's habeas rule directing transfer to the district of conviction. Because Lawson challenges his conviction and Butte County is within the Eastern District of California, the court determined that the proper venue was the Eastern District.

Ruling

Judge Susan Van Keulen ordered the case transferred to the Eastern District of California in the interest of justice. The clerk was directed to transfer the matter immediately. The order transferred the case; it did not decide the validity of the conviction or the merits of the habeas petition.