Griffin v. People of State of California
- Edward Davila
- 5:20-cv-07539
- U.S. District Court · Northern District of California
- 2
Griffin v. People of State of CA: Judge Davila transferred the prisoner’s conviction challenge to the Eastern District of California because venue was there.
Dexter L. Griffin, whose federal petition challenging his conviction was transferred from the Northern District of California to the Eastern District of California; the merits of his claims were not decided.
What happened
In Griffin v. People of State of CA, Dexter L. Griffin, a state prisoner representing himself, filed a petition challenging his conviction under federal law. He was confined at Coalinga State Hospital and appeared to raise new claims about that conviction.
The court explained that a prisoner’s challenge may be heard where the prisoner is confined or where the conviction occurred. Griffin was convicted in Sacramento County and was confined in Fresno County, both in the Eastern District of California, so the Northern District was not the proper venue.
Judge Edward J. Davila transferred the case and its entire file to the Eastern District of California. The clerk was directed to terminate all pending motions.
The detailed version
- Griffin v. People of State of California · No. 5:20-cv-07539
- Edward Davila
- Mar. 5, 2021
Background
Dexter L. Griffin, a state prisoner proceeding without a lawyer, filed a petition under 28 U.S.C. § 2254 challenging his underlying conviction. The opinion states that he was confined at Coalinga State Hospital and appeared to be raising new claims concerning that conviction. Griffin had previously filed a related habeas case that was transferred to the Eastern District of California.
Venue analysis
For a petition challenging a state conviction, federal law permits venue in either the district where the prisoner is confined or the district where the conviction occurred. The court stated that Griffin was convicted in Sacramento County, which is in the Eastern District of California, and was confined in Fresno County, which is also in that district. The court therefore concluded that the proper venue was the Eastern District of California rather than the Northern District of California.
Disposition
The court transferred the case to the United States District Court for the Eastern District of California under 28 U.S.C. § 1406(a) and the district’s habeas rules. The clerk was ordered to terminate all pending motions and transfer the entire file. Judge Edward J. Davila signed the order. The opinion did not decide the merits of Griffin’s conviction-related claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.