Williams v. Superior Court of Sacramento County
- Susan Van Keulen
- 5:23-cv-00305
- U.S. District Court · Northern District of California
- 2
In Williams v. Superior Court of Sacramento County, Magistrate Judge Van Keulen transferred a prisoner’s conviction challenge to the Eastern District of California.
Anthony James Williams’s conviction challenge and request for appointed counsel were transferred for handling by the Eastern District of California.
What happened
Williams v. Superior Court of Sacramento County involves a California prisoner’s petition challenging the validity of a Sacramento County conviction. Williams filed the petition without a lawyer in the Northern District of California.
The court determined that challenges to a state conviction should generally be heard in the federal district where the conviction occurred. Because Sacramento County is in the Eastern District of California, the court transferred the case there.
Magistrate Judge Susan Van Keulen also deferred the request for appointed counsel to the Eastern District and directed the clerk to transfer the case and terminate that motion from the Northern District’s docket.
The detailed version
- Williams v. Superior Court of Sacramento County · No. 5:23-cv-00305
- Susan Van Keulen
- Jan. 30, 2023
Background
Anthony James Williams, a California prisoner proceeding without an attorney, filed a petition under 28 U.S.C. § 2254 challenging the validity of his conviction in Sacramento County Superior Court.
Venue analysis
Under 28 U.S.C. § 2241(d), a state prisoner’s petition may be filed in the federal district where the prisoner is confined or in the district where the conviction occurred. Those districts have concurrent jurisdiction, but the district where the petition was filed may transfer it to the other district in the interest of justice. The court explained that federal courts in California have traditionally heard challenges to a conviction or sentence in the district where the conviction occurred.
Because Williams challenged a Sacramento County conviction, the court concluded that the proper venue was the Eastern District of California. Sacramento County lies within that district.
Ruling
The court transferred the case to the United States District Court for the Eastern District of California. It deferred ruling on Williams’s motion for appointment of counsel to that court, directed the clerk to terminate the motion from the Northern District’s docket, and ordered the matter transferred promptly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.