Bailey v. Santa Clara County Superior Court

Background

Jasper Bailey, an incarcerated person proceeding without a lawyer, brought an action under 42 U.S.C. § 1983 against Santa Clara County Superior Court. He challenged the court’s denial of his request for testing of potentially exculpatory DNA evidence obtained in 2018 and argued that he had a constitutional right to that testing.

On March 25, 2021, the court allowed Bailey to proceed without paying the filing fee, dismissed the action with prejudice, and entered judgment for the defendant. The court held that the Rooker-Feldman doctrine barred the action. That doctrine generally prevents lower federal courts from reviewing state-court decisions. The court relied on Ninth Circuit authority holding that a challenge to a state court’s denial of DNA testing under California Penal Code § 1405 was barred by that doctrine, even when the challenge was presented as a federal constitutional claim.

Request for Reconsideration

Bailey filed a notice of appeal and objections to the dismissal. The court treated the objections as a motion for reconsideration. Bailey did not specify whether he was seeking relief under Federal Rule of Civil Procedure 59(e), which permits a court to alter or amend a judgment, or Rule 60(b), which permits relief from a judgment for specified reasons.

Bailey argued that the court had erred because he cited Proposition 69, because federal law was supreme and federal courts could review state-court decisions, and because he had identified damages and due-process violations arising from his pretrial arrest, the adequacy of his trial lawyer’s representation, and alleged witness tampering by the trial judge.

Court’s Analysis

The court rejected Bailey’s first two arguments. It explained that Proposition 69 is a California state proposition that modified state law and does not create rights under federal law or the federal Constitution. The court also explained that state-court litigants may seek federal review of a state-court judgment by petitioning the United States Supreme Court, but lower federal courts lack subject-matter jurisdiction to review those decisions.

The court stated that it had not made findings about whether Bailey was harmed and had not considered his claims concerning his arrest, trial lawyer, or alleged witness tampering. Instead, the earlier dismissal rested on the Rooker-Feldman doctrine. The court concluded that it had committed neither clear error nor a mistake.

Disposition

The court denied Bailey’s motion for reconsideration. The case remains closed, and the order terminated docket entry 22.