Godfrey v. Warden PVSP

Background

JM Godfrey, a state prisoner proceeding without a lawyer, filed a petition under Section 2254 asking for federal review of the denial of resentencing under California Senate Bill 620. The petition stated that he had pleaded no contest in 2010 to several offenses, including felony carjacking, second-degree robbery, and two counts of felony assault with a semiautomatic firearm, along with firearm and other sentencing enhancements. The petition did not clearly state the terms of his sentence.

Godfrey did not appeal his judgment. He filed state petitions in 2019, and California’s highest court denied one on January 22, 2020. The state superior court had ruled that Senate Bill 620 did not apply retroactively to final judgments; the state appellate and high courts later summarily denied his petitions.

Court’s Analysis

The court explained that federal habeas relief is available to a state prisoner only for custody that violates the Constitution, federal law, or a treaty. It also explained that a habeas petition must state specific grounds and supporting facts, and that the court must dismiss a petition when it plainly shows that the petitioner is not entitled to relief.

The court concluded that Godfrey’s challenge to Senate Bill 620 involved the interpretation and application of California sentencing law. A state court’s alleged mistake in applying its own sentencing law does not ordinarily create a federal habeas claim, absent fundamental unfairness. The court stated that merely describing the state-law issue as a federal constitutional violation was insufficient.

The court also found that Godfrey had not exhausted his Eighth Amendment claim in state court. It said his reliance on the rule concerning certificates of appealability was premature. The court further stated that it was bound by the state court’s interpretation that Senate Bill 620 did not apply retroactively to final judgments and that, even if the state court had misapplied the statute, Godfrey had not presented a federal habeas claim.

Disposition

The court dismissed the petition for lack of federal habeas jurisdiction. It found that no certificate of appealability was warranted and denied one. It denied as moot Godfrey’s motion for appointment of counsel because of the dismissal and denied as moot his motion to proceed without paying the filing fee because he had already provided proof of payment. Judge Beth Labson Freeman signed the order on June 30, 2020.