McCarter v. People of California
- Donna Ryu
- 4:22-cv-01111
- U.S. District Court · Northern District of California
- 2
In McCarter v. Broomfield, Judge Ryu transferred a state prisoner’s conviction challenge to the Eastern District of California without deciding its merits.
Steven A. McCarter’s federal challenge to his Sacramento County conviction was moved from the Northern District of California to the Eastern District of California; the court did not decide the challenge.
What happened
Steven A. McCarter, a state prisoner at San Quentin State Prison, filed a self-represented petition challenging the validity of his conviction from Sacramento County Superior Court. The case was filed in the Northern District of California.
Because the petition challenges the conviction and sentence, rather than how the sentence is being carried out, the court determined that the Eastern District of California was the proper district. Sacramento County is within that district.
Judge Donna M. Ryu ordered the case transferred to the Eastern District of California under federal venue and habeas-transfer rules. The court did not decide whether McCarter’s conviction challenge was valid.
The detailed version
- McCarter v. People of California · No. 4:22-cv-01111
- Donna Ryu
- Mar. 10, 2022
Background
Steven A. McCarter, identified as a state prisoner incarcerated at San Quentin State Prison, filed a self-represented petition under 28 U.S.C. § 2254 challenging the validity of a conviction obtained in Sacramento County Superior Court. Ron Broomfield, the current warden of the prison, was substituted as the respondent under Federal Rule of Civil Procedure 25(d). The Northern District of California had also sent McCarter a notice about completing an application to proceed without paying the filing fee.
Venue analysis
Federal law allows a state prisoner’s petition challenging a state-court judgment to be filed either in the federal district where the prisoner is confined or in the district where the prisoner was convicted. The court may transfer the petition to the other district when doing so serves the interests of justice. The court explained that California federal courts traditionally hear challenges to a conviction or sentence in the district where the conviction occurred. Claims about how a sentence is being carried out, such as parole or time-credit claims, are more appropriately heard where the prisoner is confined.
McCarter challenged his conviction and sentence from Sacramento County Superior Court. Because Sacramento County is within the Eastern District of California, the court stated that the Eastern District had jurisdiction over the matter.
Disposition
Under 28 U.S.C. § 1406(a) and Habeas Local Rule 2254-3(b), and in the interest of justice, the court transferred the action to the United States District Court for the Eastern District of California. The Clerk was directed to transfer the case immediately. The order did not address the merits of McCarter’s conviction challenge.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.