Stull v. Smith
- Jon Tigar
- 4:23-cv-04756
- U.S. District Court · Northern District of California
- 4
In Stull v. Broomfield, Judge Tigar dismissed one habeas claim with prejudice and ordered a response on another challenging prison discipline.
James Conrad Stull’s federal habeas petition challenging his prison disciplinary decision; Ron Broomfield was ordered to respond to the remaining claim.
What happened
In Stull v. Broomfield, James Conrad Stull, who is incarcerated at San Quentin State Prison and representing himself, challenged a prison disciplinary decision that resulted in the loss of 180 days of credits. He claimed the decision lacked supporting evidence and that his disciplinary hearing was delayed under California regulations.
The court found that the evidence-based claim could proceed as a federal habeas claim. It dismissed the claim about the hearing deadline with prejudice because an alleged violation of that state regulation did not by itself establish a violation of federal law. The court ordered Ron Broomfield to respond to the remaining claim.
Judge Jon S. Tigar issued the order on November 17, 2023. The order required Broomfield to file an answer or a motion to dismiss on procedural grounds within 91 days, after which Stull could reply.
The detailed version
- Stull v. Smith · No. 4:23-cv-04756
- Jon Tigar
- Nov. 17, 2023
Background
James Conrad Stull, an incarcerated person at San Quentin State Prison, filed a petition for federal habeas relief under 28 U.S.C. § 2254 without a lawyer. He challenged a prison disciplinary decision rather than his robbery conviction or sentence. The disciplinary matter began with a rules violation report accusing Stull of conspiring to introduce controlled substances for distribution after heroin was found inside mail addressed to him. Stull was found guilty and lost 180 days of good-time and work-time credits. He reported that his state-court challenges to the disciplinary conviction and credit loss were unsuccessful.
Claims and screening
The court reviewed the petition under the initial screening procedures for § 2254 cases. Stull raised two claims: that there was not “some evidence” supporting the guilty finding, and that the disciplinary hearing was not held within the time required by 15 California Code of Regulations § 3316(c)(1)(A).
The court explained that federal due process in prison disciplinary proceedings requires specified procedural protections, including some reliable evidence supporting the decision. It held that Stull’s first claim was legally sufficient to proceed because it alleged that the guilty finding lacked “some evidence.” The court did not decide whether that claim would ultimately succeed.
The court held that the second claim alleged only a violation of state law. Federal due process does not require a prison to follow procedures that provide more protection than federal law requires. The court therefore dismissed with prejudice the second claim for failure to state a claim for federal habeas relief.
Order
The court ordered Ron Broomfield to file an answer within 91 days explaining why habeas relief should not be granted on the remaining evidence-based claim. Broomfield could instead file a motion to dismiss on procedural grounds within that period. The court also set deadlines for Stull’s response and reminded him to serve court communications on opposing counsel, keep the court informed of address changes, and comply with court orders.
Classification
This is a procedural order. The court dismissed one claim during initial screening and allowed another claim to proceed for a response; it did not finally decide the merits of the remaining claim.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.