Pedro Medina Castillon v. The People of the State of California
- Edward Chen
- 3:21-cv-00973
- U.S. District Court · Northern District of California
- 3
In Pedro Medina Castillon v. The People, Judge Chen dismissed the amended federal habeas petition with leave to amend because four claims did not identify federal rights.
Pedro Medina Castillon’s amended federal habeas petition was dismissed with leave to amend; Claims 1–3, 7, 9, and 10 remained potentially cognizable, while Claims 4–6 and 8 required a stated federal constitutional basis.
What happened
Pedro Medina Castillon, who was representing himself, filed a federal challenge to his state-court custody. The court had previously found that six of his ten claims could proceed but that Claims 4–6 and 8 relied only on state law or did not identify a federal right.
In his amended petition, Castillon cited a California appellate decision for Claim 4 and cited federal appellate decisions without explaining the federal rights involved in Claims 5, 6, and 8. The court said a federal custody challenge must be based on a violation of the U.S. Constitution, federal law, or a treaty—not merely a violation or misinterpretation of state law.
Judge Chen dismissed the amended petition with leave to amend and gave Castillon one final opportunity to identify the federal constitutional rights allegedly violated by the trial court’s evidence rulings and jury instruction. If Castillon does not file a second amended petition by June 3, 2022, the case will proceed only on Claims 1–3, 7, 9, and 10.
The detailed version
- Pedro Medina Castillon v. The People of the State of California · No. 3:21-cv-00973
- Edward Chen
- Apr. 28, 2022
Background
Pedro Medina Castillon, an inmate, filed this self-represented petition for a federal writ of habeas corpus under 28 U.S.C. § 2254. The court previously reviewed the petition under the federal habeas screening rules and dismissed it in part. It determined that Claims 1–3, 7, 9, and 10 were legally cognizable, while Claims 4–6 and 8 could not proceed because they identified only violations of California law. The court allowed Castillon to amend those claims.
Castillon filed an amended petition. The court reviewed it again under the federal habeas screening rules.
Court’s Analysis
The court explained that a person held under a state-court judgment may obtain federal habeas relief only by showing custody in violation of the U.S. Constitution, federal law, or a treaty. Federal habeas relief generally is not available for violations of state law or alleged mistakes in interpreting or applying state law.
The court found that the amended petition still did not identify a federal constitutional right for Claims 4–6 and 8. Claim 4 cited only a California appellate decision. Claims 5 and 6 cited Ninth Circuit decisions without explanation and discussed a California appellate decision at length. Claim 8 cited Ninth Circuit decisions but did not discuss any federal right. The court instructed Castillon to identify the federal constitutional right allegedly violated when the trial court excluded evidence in Claims 4–6 and gave the jury instruction challenged in Claim 8.
Disposition
The court dismissed the amended petition with leave to amend. It gave Castillon one last opportunity to file a complete second amended petition curing the identified deficiencies by June 3, 2022. If he does not do so, the case will proceed only on Claims 1–3, 7, 9, and 10, which the court had previously determined were cognizable. Judge Edward M. Chen signed the order on April 28, 2022.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.