Griffin v. People of the State of California
- Edward Davila
- 5:19-cv-07698
- U.S. District Court · Northern District of California
- 2
In Dexter L. Griffin v. People of California, Judge Davila transferred Griffin’s habeas case to the Eastern District of California because venue was improper.
Dexter L. Griffin’s federal habeas petition was transferred from the Northern District of California to the Eastern District of California; the court did not decide the merits of his claims.
What happened
Dexter L. Griffin, a state prisoner representing himself, filed a petition challenging either his time-credit calculation or his Sacramento County conviction. The court noted that the petition’s exact target was unclear.
The court ruled that the case belonged in the Eastern District of California because Griffin was convicted in Sacramento County and confined in Fresno County, both within that district. It transferred the entire case file there and terminated all pending motions.
Judge Edward J. Davila issued the transfer order in Griffin v. People of the State of CA. The court did not decide the substance of Griffin’s habeas claims.
The detailed version
- Griffin v. People of the State of California · No. 5:19-cv-07698
- Edward Davila
- Feb. 7, 2020
Background
Dexter L. Griffin, a state prisoner proceeding without a lawyer, filed a petition under 28 U.S.C. § 2254. The opinion says it was unclear whether he challenged the calculation of his time credits or the underlying conviction from Sacramento County.
Venue analysis
For a state-prisoner habeas case, venue is proper in either the federal district where the prisoner is confined or the district where the conviction occurred. The court explained that federal courts in California traditionally hear challenges to a conviction or sentence in the district where the conviction or sentencing occurred, while challenges to how a sentence is carried out may be heard in the district of confinement.
Griffin was convicted in Sacramento County, which is in the Eastern District of California. He was confined at Coalinga State Hospital in Fresno County, which is also in the Eastern District. The court therefore concluded that venue was in the Eastern District rather than the Northern District.
Ruling
The court transferred the case to the United States District Court for the Eastern District of California under 28 U.S.C. § 1406(a) and the district’s habeas rules. The clerk was ordered to terminate all pending motions and transfer the entire file. Judge Edward J. Davila did not decide whether Griffin was entitled to habeas relief or resolve the substance of his claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.