Lacy v. Miyamoto

Background

Roy D. Lacy, a state prisoner incarcerated at San Francisco County Jail, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254 without a lawyer. He challenged a Marin County Superior Court conviction for robbery under California Penal Code § 211. The opinion states that a Marin County jury convicted him, that he was sentenced in February 2016 to 105 years to life, that a state appellate court affirmed the conviction and sentence in 2016, and that the California Supreme Court denied review in 2018.

Lacy raised two claims: that the trial court admitted statements obtained in violation of the warnings and protections required by Miranda v. Arizona and Edwards v. Arizona, and that the trial court improperly admitted evidence of his prior crimes. The court found that, when read generously, these claims could support federal habeas relief and therefore required a response. The court also noted that the petition might be barred by the one-year limitation period under the Anti-Terrorism and Effective Death Penalty Act, but it did not decide that issue in this order.

Respondents

Lacy named Sheriff Paul Miyamoto and Attorney General Xavier Becerra as respondents. The court explained that a habeas petition challenging present physical confinement generally has one proper respondent: the prisoner’s immediate custodian, usually the official responsible for the facility where the prisoner is held. The court concluded that Sheriff Miyamoto was the only proper respondent and dismissed Attorney General Xavier Becerra from the action. The clerk was directed to correct the spelling of the remaining respondent’s name in the docket from “Myamoto” to “Miyamoto.”

Filing-fee request and counsel

The court granted Lacy’s request to proceed in forma pauperis, meaning without prepaying the filing fee. It denied his request for appointment of counsel. The court stated that Lacy had given no reason showing that counsel was needed and that the record did not show that appointing counsel was required in the interests of justice. The denial was stated to be without prejudice to the court appointing counsel later if circumstances require it.

Order to respond

The court ordered the remaining respondent to file and serve an answer within 60 days explaining why the writ should not be granted and to provide relevant portions of the transcribed state trial record. Instead of an answer, the respondent could file a motion to dismiss on procedural grounds within that period. If an answer is filed, Lacy may file a response within 30 days; if a procedural motion is filed, the order sets deadlines for Lacy’s opposition and the respondent’s reply.

This order screened the petition and set the next steps. It did not decide whether Lacy’s conviction or sentence violated federal law, and it did not grant or deny habeas relief.