Griffin v. Price
- Edward Davila
- 5:21-cv-07661
- U.S. District Court · Northern District of California
- 3
In Griffin v. Price, Judge Davila transferred Griffin’s habeas petition to the Eastern District of California because he was confined there.
Dexter Lawrence Griffin’s petition was transferred from the Northern District of California to the Eastern District of California; respondent Brandon Price was named in the petition.
What happened
In Griffin v. Price, Dexter Lawrence Griffin, a state patient at Coalinga State Hospital, challenged the retroactive application of California’s Sexually Violent Predator Act in a petition filed without a lawyer. He filed the petition under a federal law allowing courts to review certain detention claims.
The court explained that Griffin was confined in Fresno County, which is within the Eastern District of California. It concluded that the Eastern District was the proper and more convenient forum for the petition.
The court transferred the petition immediately to the Eastern District of California without deciding Griffin’s challenge. Judge Edward J. Davila signed the order.
The detailed version
- Griffin v. Price · No. 5:21-cv-07661
- Edward Davila
- Oct. 8, 2021
Background
Dexter Lawrence Griffin, identified as a state patient at Coalinga State Hospital, filed a petition without a lawyer under 28 U.S.C. § 2241. He challenged the retroactive application of the Sexually Violent Predator Act. The respondent is Brandon Price.
Reasoning
Section 2241 allows federal courts to issue detention-review orders within their respective jurisdictions. The court explained that challenges to the manner, location, or conditions of confinement generally should be brought in the federal district where the petitioner is confined. Coalinga State Hospital is in Fresno County, which lies within the Eastern District of California.
The court further explained that the district of confinement is generally the most convenient forum because the relevant records are there and because handling these petitions in that district promotes consistency. It determined that the Eastern District of California appeared to be the proper forum and that transfer would not create undue delay.
Disposition
In the interests of justice, the court exercised its discretion to TRANSFER the petition forthwith to the Eastern District of California. The order did not decide whether the retroactive application of the Sexually Violent Predator Act was lawful.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.