Trammell v. People of State of California
- Edward Davila
- 5:20-cv-02367
- U.S. District Court · Northern District of California
- 4
In Trammell v. State of California, Judge Davila dismissed the custody petition for lack of jurisdiction, denied fee-waiver status, and ordered a separate case opened.
Nicholas Trammell; the order dismissed his federal petition challenging the $350 infraction, denied his request to proceed without paying the filing fee, and required his challenge to a different conviction to proceed in a separate action.
What happened
Nicholas Trammell asked a federal court to review a $350 light-rail infraction. He said he was imprisoned for a different Stanislaus County matter, not for the infraction.
The court ruled that success on the infraction challenge would not change the sentence he was serving, so the petition did not meet the custody requirement for federal review. The court also denied his request to avoid paying the filing fee because his account showed a balance of $283.29.
In Trammell v. State of California, Judge Davila dismissed the petition for lack of jurisdiction, denied the fee-waiver request, denied another motion as moot, and directed the clerk to open a separate case for Trammell's challenge to a different conviction. The court also found that no appeal certificate was warranted.
The detailed version
- Trammell v. People of State of California · No. 5:20-cv-02367
- Edward Davila
- Jan. 20, 2021
Background
Nicholas Trammell, representing himself, filed a petition under 28 U.S.C. § 2254 asking the federal court to review a $350 infraction involving light rail in Santa Clara County. He stated that he was currently imprisoned for a “Stanislaus County matter” and not for the infraction he was challenging. He also said he had not appealed the infraction in state court.
The action had previously been dismissed because Trammell did not timely file a complete application to proceed without paying the filing fee. It was later reopened after an application was docketed as having been filed before the judgment but posted after the case had closed.
Custody Requirement and Jurisdiction
Federal review under § 2254 is available only for a person who is in custody and whose claim is connected to the custody that allegedly violates federal law. The court explained that the claim must be one where success would change the restraint on the person's liberty.
The court found that Trammell satisfied the first custody requirement because he was imprisoned. But it found no connection between the challenged $350 infraction and the Stanislaus County conviction and sentence for which he was confined. Even if Trammell prevailed on the infraction challenge, the court said, that result would not change his current imprisonment. The court therefore concluded that it lacked jurisdiction over the petition.
Other Motions and Filings
The court denied Trammell's application to proceed without paying the filing fee because the supporting records showed an available balance of $283.29, which the court found did not establish sufficient financial hardship. The court denied as moot a separate, illegible motion concerning a purported out-of-state carjacking charge because it could not determine the motion's relevance and had found no jurisdiction over the challenged matter.
A filing concerning alleged voting fraud and damages for mental anguish did not fit within the custody challenge. The court stated that, to the extent Trammell sought damages against state actors for constitutional violations, he would need to bring that claim in a separate action under 42 U.S.C. § 1983.
Trammell also filed another document titled “petition for writ of habeas corpus” challenging a rape conviction and related charges from Stanislaus County. The court determined that this concerned a different conviction and sentence and directed the clerk to open it as a separate federal habeas action, using September 28, 2020, as that action's filing date, and to send Trammell information about paying the fees or applying for a fee waiver.
Ruling
Judge Davila dismissed the petition for lack of jurisdiction. The court denied Trammell's motion to proceed without paying the filing fee, denied the other motion as moot, and stated that no certificate of appealability was warranted because a reasonable judge would not find the dismissal debatable or wrong. The order terminated Docket No. 7.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.