Bailey v. Santa Clara County Superior Court

Background

Jasper Bailey, an inmate at Correctional Training Facility in Soledad, California, filed this action without a lawyer under 42 U.S.C. § 1983. The court reviewed the complaint under the prisoner-screening statute, 28 U.S.C. § 1915A. Bailey sued the Santa Clara County Superior Court over its denial of his request to test potentially exculpatory DNA evidence obtained in 2018. He argued that he had a constitutional right to DNA testing but did not identify a federal law or constitutional provision supporting that argument.

Bailey also made challenges to his conviction and the length of his incarceration. The court did not address those claims because Bailey identified the state court’s denial of DNA testing as the subject of this action. The court stated that challenges to the legality of a conviction or the duration of a sentence must be brought through a petition for release from unlawful custody under 28 U.S.C. § 2254, rather than through a § 1983 action. The opinion also stated that Bailey had already filed such a petition and would need prior authorization from the U.S. Court of Appeals for the Ninth Circuit before filing a second or successive petition challenging that conviction.

Ruling

The court dismissed the action with prejudice because the Rooker-Feldman doctrine barred it. That doctrine prevents federal district courts from reviewing state-court judgments; the court concluded that Bailey’s complaint challenged the particular outcome of the state court’s decision denying DNA testing. The court relied on precedent holding that labeling such a challenge as constitutional does not avoid the doctrine. Judge Haywood S. Gilliam, Jr. denied all pending motions as moot, directed the clerk to enter judgment in favor of Defendants and against Plaintiff, and ordered the file closed.