Ajaelo v. Madden

Background

Jideofor Ajaelo, a California prisoner proceeding without a lawyer, filed a petition under 28 U.S.C. § 2254 challenging his state-court conviction. In 2007, he was convicted of first-degree murder with special circumstances and attempted first-degree murder. The state court sentenced him to 25 years to life without parole. His direct appeals to the California Court of Appeal and the California Supreme Court were unsuccessful. The California Supreme Court also recently denied, without prejudice, a state petition challenging his custody.

Ajaelo asked to proceed without paying court fees and moved for a stay under a procedure that can pause a federal case while a petitioner pursues additional claims in state court.

Claims and screening

The court reviewed the petition under the heightened pleading standards governing federal petitions challenging state custody. A petitioner must identify each ground for relief and briefly state the supporting facts; general notice pleading is not enough.

Ajaelo asserted four claims: that his first-degree-murder conviction was based on an invalid legal theory; that he received ineffective assistance of counsel; that his attempted-murder convictions were based on an invalid legal theory; and that his sentence was invalid under state law. The court concluded that the first and third claims implicated due process, and that the second implicated the Sixth Amendment right to counsel. The court concluded that the fourth claim, because it was based on state law, did not provide a basis for federal habeas relief.

Rulings and next steps

The court ordered the respondent to show cause why relief should not be granted based on the first three claims. This was an order requiring the respondent to respond; it did not decide whether Ajaelo ultimately should win those claims.

The court denied the motion for a stay because Ajaelo did not identify additional unexhausted claims that he wished to pursue in state court. The court granted the motion for leave to proceed without paying court fees.

The clerk was ordered to serve the order and petition on the respondent and the respondent’s attorney, identified as the Attorney General of California. Within 91 days, the respondent had to file an answer complying with the rules for these petitions or file a motion to dismiss on procedural grounds instead. If an answer was filed, Ajaelo could file a response within 28 days. The order also required Ajaelo to serve his court filings on opposing counsel, keep the court informed of address changes, and comply with court orders. The order stated that failure to do so could result in dismissal for failure to prosecute.