Taylor v. Jaime
- Susan Illston
- 3:19-cv-05664
- U.S. District Court · Northern District of California
- 3
In Taylor v. Jaime, Judge Gilliam granted Namon Taylor’s request to stay his federal habeas case while he exhausted additional claims.
Namon Taylor’s federal habeas action is paused and administratively closed until he moves to reopen it and lift the stay.
What happened
In Taylor v. Jaime, Namon Taylor, a state prisoner, asked the federal court to pause his challenge to his state convictions. The court had already recognized three possible claims, involving trial evidence, trial counsel, and evidence seized by police.
Taylor said he had found two additional constitutional claims while reviewing recently received trial transcripts. He reported that he was pursuing those claims in state court and asked the federal court to wait so he could finish that process before adding them to his federal case.
Judge Gilliam granted the request to stay the case. The court administratively closed the action, and nothing further will occur unless Taylor asks to reopen it and lift the stay.
The detailed version
- Taylor v. Jaime · No. 3:19-cv-05664
- Susan Illston
- Nov. 27, 2019
Background
Namon Taylor, a state prisoner, filed a self-represented petition under 28 U.S.C. § 2254 asking the federal court to review his state-court convictions. The opinion states that an Alameda County Superior Court convicted him on June 14, 2016, of two robberies and possessing a firearm as a felon, and sentenced him to 15 years in state prison. The state appellate court later sent the case back to consider whether to impose a firearm-use enhancement while affirming the judgment in all other respects. The California Supreme Court denied review.
Taylor also pursued state post-conviction petitions, which were denied by the Alameda County Superior Court, the California Court of Appeals, and the California Supreme Court. He filed this federal petition on September 9, 2019. On October 10, 2019, the court found three claims that could support federal habeas relief: that evidence of an uncharged crime improperly reduced the prosecution’s burden of proof; that trial counsel was ineffective for failing to investigate before trial, including by failing to challenge a search of Taylor’s car trunk; and that police illegally seized evidence.
Request to Stay
Taylor asked the court to pause the federal case while he exhausted additional claims in state court. He said he had only recently received the trial transcripts and had identified two additional constitutional violations while reviewing them. He stated that he had already filed a second state habeas petition concerning those claims and intended to amend his federal petition after completing state-court review. He also stated that his one-year filing deadline would not expire until approximately June 2020.
Ruling
The court granted Taylor’s motion to stay and hold the proceedings in abeyance. The court stated that the filing period did not appear to have expired and that Taylor did not appear to be using an intentionally delaying litigation tactic. The action was stayed and administratively closed. Nothing further will take place unless Taylor moves to reopen the action and lift the stay. The order terminated Docket No. 12; it did not decide the merits of Taylor’s habeas claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.