Patterson v. People of California
- Haywood Gilliam
- 4:21-cv-05430
- U.S. District Court · Northern District of California
- 3
In Patterson v. Matteson, Judge Gilliam dismissed Patterson’s petition without prejudice for lack of jurisdiction and denied a certificate of appealability.
Norman B. Patterson’s § 2254 petition was dismissed for lack of jurisdiction, but the court stated that the challenge could be asserted in a new civil-rights action. G. Matteson received judgment in his favor in this case.
What happened
Patterson v. Matteson concerned Norman B. Patterson’s petition challenging his 2003 California murder conviction and life-without-parole sentence. He sought a youth-offender parole hearing under California Penal Code section 3501(h).\n\nPatterson argued that excluding people serving life-without-parole sentences from that process violated equal protection. The court ruled that a parole hearing would not necessarily shorten his sentence, so this challenge could not be brought through a petition challenging the legality or duration of imprisonment.\n\nJudge Haywood S. Gilliam, Jr. dismissed the petition for lack of jurisdiction without prejudice to a new civil-rights action, denied a certificate of appealability, granted Patterson’s application to proceed without paying filing fees, and denied as moot his motion to correct the record or recall his sentence.
The detailed version
- Patterson v. People of California · No. 4:21-cv-05430
- Haywood Gilliam
- Aug. 24, 2021
Background
Norman B. Patterson filed a petition under 28 U.S.C. § 2254 challenging his 2003 Alameda County Superior Court conviction and sentence for first-degree murder. The petition states that he was sentenced to life without parole on July 7, 2003. The case was reviewed under the federal rules governing these petitions.
Patterson sought eligibility for a youth-offender parole hearing under California Penal Code § 3501(h). He argued that the law’s exclusion of youthful offenders serving life-without-parole sentences violated the Equal Protection Clause. The court also noted that Patterson originally filed a motion asking the court to correct or recall his sentence, and the clerk instructed him to file a complete petition.
Jurisdictional Analysis
The court explained that a petition under § 2254 is available for a challenge to the fact or duration of confinement. A civil-rights action under 42 U.S.C. § 1983 is the proper vehicle when success would not necessarily shorten the person’s sentence.
Because a youth-offender parole hearing would not guarantee parole, the court concluded that eligibility for such a hearing would not necessarily result in Patterson’s immediate or faster release. The court therefore held that it lacked jurisdiction over Patterson’s petition. The court stated that the dismissal was without prejudice to Patterson filing a new civil-rights action asserting his challenge to § 3501(h).
Disposition
The court dismissed the petition for lack of jurisdiction. It denied a certificate of appealability because Patterson had not shown that reasonable judges could debate whether the petition stated a valid constitutional claim and whether the court’s procedural ruling was correct.
The court granted Patterson’s application to proceed without paying filing fees. It denied as moot Patterson’s motion to correct the record or recall his sentence, directed the clerk to enter judgment in favor of G. Matteson, terminated the specified docket entries and pending motions as moot, and closed the file.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.