Peters v. Madden
- Edward Davila
- 5:22-cv-06480
- U.S. District Court · Northern District of California
- 3
In Peters v. Madden, Judge Kim granted Darren Michael Peters permission to proceed without fees and ordered the respondent to answer his arguably cognizable habeas claim.
Darren Michael Peters’s federal challenge to his state conviction and sentence will proceed to the response stage; Raymond Madden and the California Attorney General’s Office must respond or file a procedural motion.
What happened
Peters v. Madden concerns Darren Michael Peters’s request for federal review of his state-court conviction and sentence. Peters, representing himself, claimed his lawyer was ineffective during plea negotiations by failing to obtain medical records or investigate a possible mental-health defense.
The court found that Peters’s claim could potentially support federal relief and required the respondent to respond. The court also described Peters’s earlier state-court filings and explained that the case would proceed under the rules for federal challenges to state custody.
Judge Kim granted Peters permission to proceed without paying filing fees and ordered the respondent to explain within 60 days why the requested relief should not be granted. The order did not decide whether Peters should ultimately win his claim.
The detailed version
- Peters v. Madden · No. 5:22-cv-06480
- Edward Davila
- Nov. 9, 2022
Background
Darren Michael Peters, a state prisoner, filed a petition under 28 U.S.C. § 2254 challenging a conviction and sentence from Napa County Superior Court. He represented himself and also asked to proceed without paying the filing fee.
According to the opinion, Peters pleaded no contest under a plea agreement to five counts of making criminal threats. On May 13, 2019, the trial court sentenced him to 16 years and four months in prison and imposed fines and fees. He appealed the fines and fees, but the California Court of Appeal affirmed the judgment on January 29, 2020. He did not seek further review from the California Supreme Court.
Peters later filed state habeas petitions claiming ineffective assistance of counsel. The Napa County Superior Court denied one petition on May 26, 2021, and the California Court of Appeal denied another on August 4, 2021. The opinion text then refers to a later petition filed on December 27, 2021, but the provided excerpt does not state the result of that proceeding.
Claim and screening
Peters claimed that his lawyer provided ineffective assistance during plea negotiations. More specifically, he alleged that counsel failed to obtain his medical records and investigate a possible mental-health defense before advising him to accept the prosecution’s plea offer.
The court explained that federal habeas relief is available to a person held under a state-court judgment only when the custody violates the Constitution, federal laws, or treaties. At this initial stage, the court concluded that Peters’s claim was “arguably cognizable” under § 2254 and therefore warranted a response from the respondent. The court did not decide the claim’s ultimate merits.
Ruling and next steps
The court granted Peters’s request to proceed without paying the filing fee. It ordered the clerk to serve the order and related materials on Raymond Madden, identified as the warden and respondent, through the California Attorney General’s Office.
The court ordered the respondent to file and serve, within 60 days, an answer showing cause why the writ should not be granted. The respondent must include relevant previously transcribed portions of the state trial record. Peters may file a response within 30 days after receiving the answer. The respondent may instead file a motion to dismiss on procedural grounds, subject to the deadlines stated in the order.
The order is a procedural step allowing the federal habeas case to proceed; it does not grant or deny the requested writ. The opinion is signed by Sallie Kim, United States Magistrate Judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.