Bates v. People of the State of California
- Jacquelyn Corley
- 3:19-cv-05499
- U.S. District Court · Northern District of California
- 3
In Bates v. People of the State of California, Judge Corley transferred the habeas petition to the Eastern District of California for proper venue.
Talmadge Bates’s federal challenge to his Solano County criminal judgment was transferred from the Northern District of California to the Eastern District of California; the Eastern District was left to decide his application to proceed without paying the filing fee.
What happened
In Bates v. People of the State of California, Talmadge Bates, a California prisoner representing himself, challenged a criminal judgment from Solano County Superior Court in a petition seeking federal review.
The Northern District of California explained that challenges to a state conviction or sentence are generally heard in the federal district where the conviction occurred. Because Solano County is in the Eastern District of California, the court transferred the case there. It deferred a decision on Bates’s application to proceed without paying the filing fee.
Judge Jacqueline Scott Corley ordered the transfer on October 24, 2019. The court did not decide whether Bates’s conviction or sentence was valid.
The detailed version
- Bates v. People of the State of California · No. 3:19-cv-05499
- Jacquelyn Corley
- Oct. 24, 2019
Background
Talmadge Bates, a California prisoner proceeding without a lawyer, filed a petition under 28 U.S.C. § 2254 challenging the validity of a criminal judgment from Solano County Superior Court.
Venue analysis
The court explained that, when a state has more than one federal judicial district, a state-prisoner habeas petition may be filed in either the district where the prisoner is confined or the district where the prisoner was convicted. The districts have concurrent jurisdiction, but the district where the petition was filed may transfer it to the other district in the interest of justice.
Because Bates challenged his conviction and sentence, the court determined that the proper venue was the district of conviction. Solano County is within the Eastern District of California.
Ruling
The court transferred the case to the United States District Court for the Eastern District of California. It deferred ruling on Bates’s application to proceed without paying the filing fee and directed the clerk to terminate that motion from the Northern District of California’s docket and transfer the matter promptly. The order did not address the merits of Bates’s challenge to his conviction or sentence.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.