Stribling v. Jordan

Background

Aaron Lamont Stribling, a California state prisoner proceeding without a lawyer, filed a federal civil-rights complaint. He had been granted permission to proceed without paying the filing fee. The court screened the complaint under 28 U.S.C. § 1915A, which requires courts to review prisoner complaints against governmental entities or officials and dismiss claims that are frivolous, seek relief from an immune defendant, or fail to state a legally sufficient claim.

Stribling was received by the California Department of Corrections and Rehabilitation on November 21, 2008, at age 19. The record stated that he was serving a total sentence of 13 years and four months for battery on emergency personnel and second-degree robbery. He argued that Proposition 57 should apply retroactively to him. He asserted that, without a prosecutor’s motion and a finding that he was unfit for juvenile court, his adult-court conviction was illegal and he should be released.

The court’s analysis

Proposition 57 amended California Welfare and Institutions Code § 707(a)(1). As relevant here, it requires a prosecutor to ask the juvenile court to transfer certain minors to adult criminal court, rather than allowing the prosecutor to begin the prosecution directly in adult court. The California Supreme Court had held that the required transfer hearing applied to juveniles charged directly in adult court whose judgments were not final when Proposition 57 took effect.

Stribling’s 2008 judgment was final before Proposition 57 was enacted. The court stated that the California Department of Corrections and Rehabilitation had therefore determined that Proposition 57 did not apply retroactively to him. Stribling alleged that this interpretation violated the California Constitution and that he was being held under an illegal sentence.

The court held that 42 U.S.C. § 1983 provides a remedy for violations of the U.S. Constitution, federal laws, or treaties—not violations of state law alone. Because Stribling did not allege that excluding him from consideration under Proposition 57 violated the U.S. Constitution or federal law, the court concluded that his complaint failed to state a claim for relief.

Ruling and effect

Judge Yvonne Gonzalez Rogers dismissed the complaint under 28 U.S.C. § 1915A(b) for failure to state a claim upon which relief could be granted. The court directed the clerk to terminate pending motions as moot and close the file. The opinion does not state that the dismissal was with or without prejudice.