Caisse v. Mattheson
- Haywood Gilliam
- 4:20-cv-03155
- U.S. District Court · Northern District of California
- 5
In Caisse v. Mattheson, Judge Gilliam dismissed the federal petition and denied permission to appeal because its claims were not legally cognizable.
Timothy M. Caisse’s federal challenge to his California conviction was dismissed, and he was denied a certificate of appealability.
What happened
Timothy M. Caisse, a California state prisoner, asked a federal court to review his 1990 second-degree murder conviction. He argued that the state court lacked authority to prosecute him because the charges began with a felony complaint rather than a grand-jury indictment.
The court said state-law errors cannot support federal review, and the federal Constitution does not require states to use grand-jury indictments. It also rejected Caisse’s arguments under the rights to notice of charges, protection from unreasonable seizure, and due process. The court further said the petition appeared to have been filed too late.
The court dismissed the petition for failure to state a legally cognizable claim for federal review and denied a certificate of appealability, which is permission to appeal. Judge Haywood S. Gilliam, Jr. issued the order.
The detailed version
- Caisse v. Mattheson · No. 4:20-cv-03155
- Haywood Gilliam
- Sept. 28, 2020
Background
Timothy M. Caisse, incarcerated at California State Prison–Solano, filed a self-represented petition under 28 U.S.C. § 2254 seeking federal review of his Contra Costa County conviction. A jury convicted him in 1990 of second-degree murder under California Penal Code § 187, and the state trial court sentenced him to 15 years to life. Caisse stated that the state appellate court denied his appeal and that the California Supreme Court denied review.
In December 2019, Caisse filed a state petition arguing that the state court lacked jurisdiction because the charges against him had not been disclosed through a grand-jury indictment. The California Supreme Court denied that petition. Caisse filed the federal petition on or about April 26, 2020. The court applied the prisoner mailbox rule to that filing date.
Claims and analysis
Caisse argued that: (1) the state court lacked jurisdiction because he was held to answer for an infamous crime without a grand-jury indictment; (2) he was not informed of the nature and cause of the charges because the prosecution began with a felony complaint; and (3) his conviction and confinement violated due process and other constitutional protections. He relied on the California Constitution and the Fourth, Fifth, Sixth, and Fourteenth Amendments to the United States Constitution.
The court held that alleged errors involving the interpretation or application of state law are not grounds for federal habeas relief. It also held that the Fifth Amendment grand-jury requirement does not apply to the states through the Fourteenth Amendment. Therefore, prosecuting Caisse through a felony complaint rather than a grand-jury indictment did not present a federal habeas claim.
The court rejected Caisse’s Sixth Amendment argument because he was informed of the charges through the felony complaint. It explained that federal law does not require notice of criminal charges through a grand-jury indictment or through a method required by state law. The court also rejected the Fourth Amendment claim because it depended on the incorrect premise that the charging procedure violated the Fifth Amendment. For the same reason, it rejected the Fourteenth Amendment procedural due process claim.
The court additionally stated that the petition appeared untimely. Federal law generally gives a person one year to challenge a state conviction, subject to specified rules delaying or pausing that period. Caisse had been sentenced nearly 30 years earlier, and the court found no basis in the record for delayed commencement or tolling. The court said Caisse had always known that he had not been charged by grand-jury indictment.
Disposition
The court dismissed the petition for failure to state a cognizable claim for federal habeas relief. It also denied a certificate of appealability because no reasonable judge would find it debatable whether the petition stated a valid constitutional claim. Judge Haywood S. Gilliam, Jr. signed the order.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.