Woods v. Broomfield

Background

Earnest C. Woods, a California state prisoner proceeding without a lawyer, filed a petition under 28 U.S.C. § 2254 challenging the denial of parole. He had been sentenced in 1987 to 17 years to life for murder and had previously challenged parole denials in two related proceedings. The court stated that he paid the filing fee.

Claims and Analysis

Woods repeated claims under the Eighth and Fifth Amendments. The court relied on its reasoning in the earlier round of this case and concluded that those claims did not warrant federal habeas relief. The opinion also referenced Woods’s earlier claims under the Sixth Amendment, the Ex Post Facto Clause, and state law, but the present petition’s repeated claims identified by the court were under the Eighth and Fifth Amendments.

Woods also argued that the parole denial violated the First Amendment right to petition the government because courts had denied his requests for appointed counsel and expert witnesses. The court found it unclear how those court decisions related to the parole-board decision being challenged. It further stated that Woods had previously been told he had no federal constitutional right to counsel at a parole hearing. Thus, a decision by the parole board or a state court denying counsel or an expert for parole proceedings did not provide a basis for federal habeas relief. The court said that any challenge to denial of counsel or experts in Woods’s criminal proceedings would have to be brought in a new petition challenging the relevant state-court judgment.

Disposition

The court dismissed the petition for failure to state grounds cognizable under federal habeas law. It ruled that Woods had not made the substantial showing required for a certificate of appealability and concluded that no certificate was warranted. The clerk was directed to enter judgment and close the file. Judge Jeffrey S. White signed the order.