Skannal v. Matteson
- Vince Chhabria
- 3:20-cv-08014
- U.S. District Court · Northern District of California
- 2
In Skannal v. Matteson, Judge Chhabria dismissed Skannal’s habeas petition without prejudice after he failed to file required documents.
Justin C. Skannal, whose federal habeas petition was dismissed without prejudice; the respondents were affected by the case’s closure.
What happened
In Skannal v. Matteson, Justin C. Skannal, a state inmate representing himself, challenged a Santa Clara County superior court judgment in a federal petition. The court had previously told him that two of his three claims relied on state law and gave him a chance to explain how they involved federal law or the Constitution.
The court also explained that his claims had not been presented to the state courts first. It gave him time to file an amended petition and a request to pause the federal case while he pursued his claims in state court. After granting his request for more time, the court received neither document and heard nothing further from him.
Judge Chhabria dismissed the petition without prejudice, meaning Skannal may refile after exhausting his federal claims. The clerk was directed to enter a separate judgment and close the case.
The detailed version
- Skannal v. Matteson · No. 3:20-cv-08014
- Vince Chhabria
- June 29, 2021
Background
Justin C. Skannal, a state inmate proceeding without a lawyer, filed a petition under 28 U.S.C. § 2254 challenging a judgment from the Santa Clara County superior court. The court had previously dismissed two of his three claims with leave to amend. It explained that those claims were based on state law, while a federal habeas petition under § 2254 may raise only violations of the U.S. Constitution, federal laws, or treaties.
The court also found that Skannal’s claims had not been exhausted in state court. Exhaustion generally means giving the state courts an opportunity to consider the federal claims before seeking federal habeas relief. The court told Skannal that he could file an amended petition explaining the federal basis for his claims, along with a request to stay the federal case while he exhausted those claims in state court. It also explained that he could instead dismiss the petition without prejudice, exhaust his federal claims, and then refile.
Procedural History
The court initially gave Skannal 28 days to file the amended petition and motion to stay. Skannal then requested a 30-day extension, which the court granted. The amended petition and motion to stay were due May 1, 2021. Skannal did not file them and did not communicate with the court.
Ruling
The court assumed that Skannal had chosen to dismiss his petition without prejudice to refiling after exhausting his federal claims. It ordered the clerk to enter a separate judgment and close the case. The order did not decide the underlying claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.