Broadnax v. Fernandez et.al.
- Jeffrey White
- 4:22-cv-04363
- U.S. District Court · Northern District of California
- 2
In Broadnax v. Fernandez, Judge White dismissed the unlawful-sentence claim without prejudice and transferred the disciplinary-proceedings claim.
Cottrell Broadnax's sentence challenge was dismissed without prejudice, and his prison-disciplinary-proceedings claim was transferred to the Eastern District of California.
What happened
In Broadnax v. Fernandez et al., Cottrell Broadnax, a California prisoner representing himself, challenged his sentence and prison disciplinary proceedings under a civil-rights law.
The court said the sentence challenge could not be brought in a civil-rights complaint and dismissed that claim without prejudice to filing it in a petition challenging the legality of his custody. The court found that the disciplinary-proceedings claim belonged in the Eastern District of California because the prison, defendants, and relevant events were there.
Judge Jeffrey S. White ordered the action transferred to the Eastern District of California in the interest of justice.
The detailed version
- Broadnax v. Fernandez et.al. · No. 4:22-cv-04363
- Jeffrey White
- Sept. 23, 2022
Background
Cottrell Broadnax, a California prisoner at Kern Valley State Prison proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. He alleged that his sentence from Alameda County Superior Court was unlawful and that disciplinary proceedings at Kern Valley State Prison were unlawful. The opinion states that the defendants were also located at Kern Valley State Prison.
Sentence claim
The court held that Broadnax could not challenge the legality of his sentence through a § 1983 civil-rights complaint. It dismissed that claim without prejudice to raising it in a petition for a writ of habeas corpus, a court petition challenging the legality of custody.
Venue and disposition
The court determined that the claim concerning the prison disciplinary proceedings belonged in the Eastern District of California. Kern Valley State Prison was within that district, and the events giving rise to that claim occurred there; the defendants were also located there. Under 28 U.S.C. § 1406(a), the court ordered the action transferred to the United States District Court for the Eastern District of California. The clerk was directed to transfer the matter forthwith.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.