Watts v. Black
- Haywood Gilliam
- 4:20-cv-00568
- U.S. District Court · Northern District of California
- 3
In Watts v. Black, Judge Gilliam dismissed Andrew B. Watts’s habeas petition for failing to present a valid federal claim and denied a certificate of appealability.
Andrew B. Watts, whose federal habeas petition was dismissed and certificate of appealability was denied; the respondent prevailed.
What happened
In Watts v. Black, Andrew B. Watts, a civil detainee at Napa State Hospital, filed a self-represented petition challenging his civil commitment. He alleged that he was not the person convicted of the underlying crimes and described a conspiracy involving medical treatment, government agencies, and courts.
The court reviewed the petition and concluded that the allegations were plainly incredible and did not claim that Watts’s custody violated federal law. It therefore found no valid basis for federal habeas relief.
The court dismissed the petition, denied a certificate of appealability, directed the Clerk to enter judgment for the respondent, and closed the case. Judge Haywood S. Gilliam, Jr. issued the order.
The detailed version
- Watts v. Black · No. 4:20-cv-00568
- Haywood Gilliam
- Mar. 9, 2020
Background
Andrew B. Watts, who was housed at Napa State Hospital, filed a self-represented petition for a writ of habeas corpus under 28 U.S.C. § 2254. He challenged his civil commitment and stated that he had previously raised these claims in a petition to the California Supreme Court, which was denied on August 15, 2018. Watts had paid the filing fee.
Claims
Watts alleged that he was not the person convicted of the underlying crimes. He claimed that he had been born under another name, later changed his name, and that the person whose name he used had been murdered. He also alleged a conspiracy to prevent him from proving his identity and innocence. His allegations included claims that doctors had injected him with substances affecting his life or memory and that Napa State Hospital and the California Department of State Hospitals had participated through forced medication, failure to follow administrative directives, restrictions on law-library access, and improper handling of personal property.
Watts further alleged that an unnamed politician and an unnamed Marine general were involved, that several courts had sealed or redacted records to conceal the truth, and that video evidence supported his claims. He asked that the relevant videos be made available to him.
Court’s analysis
The court reviewed the petition under 28 U.S.C. § 2243 and Rule 4 of the rules governing federal petitions under § 2254. A court may summarily dismiss a petition when its allegations are vague or conclusory, plainly incredible, or clearly frivolous or false. The court found that Watts’s claims were “palpably incredible” and that he had not alleged that his custody violated federal law. It therefore concluded that he had not stated any claim that could be addressed through federal habeas relief.
Disposition
The court dismissed the petition. It also denied a certificate of appealability because Watts had not shown that reasonable judges could debate whether the petition stated a valid constitutional claim. The Clerk was directed to enter judgment for the respondent and close the file. Judge Haywood S. Gilliam, Jr. issued the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.