Petitions for Habeas Corpus in Federal Court
|
 |
The Writ of Habeas Corpus
**Please Note: In the Andrade case, the U.S. Supreme Court held that the "proportionality" test under the 8th Amendment "cruel and unusual" clause was not a
"clearly established" rule and therefore Andrade's sentence affirmed by the California appellate process should have been upheld--thus basically only allowing for a direct writ to the U.S. Supreme Court on the issue.
The writ of habeas corpus is a means by which a court questions the
legality of a persons imprisonment. When a court issues a writ of habeas
corpus, the party holding the prisoner must respond to the court, explaining
the legal justification for the custody. If the court is not satisfied that
there is legal justification for the custody, it may order the prisoner
released.
The right to petition for a writ of habeas corpus is
protected by the United States Constitution (Article I, section 9) and governed
by federal statutes. The statutes governing habeas corpus in federal courts
generally are found in Title 28 of the United States Code at sections 2244
through 2266. The section particularly important for persons in state custody
is
section 2254 .
The federal courts will grant relief to a petitioner
for a writ of habeas corpus only if
- the state court decision was contrary to or involved an unreasonable
application of clearly established federal law, as determined by the Supreme
Court of the United States; or
- the decision was based on an unreasonable determination of the facts
in light of the evidence presented in the state court proceeding. (The state
court's determination of a factual issue will be presumed to be correct,
however, and you have the burden of rebutting that presumption by clear and
convincing evidence.)
Prerequisites for Filing a Petition
There are certain prerequisites for filing a petition for habeas corpus
in federal court.
- The petitioner must be in custody. Custody includes prison, parole
and probation.
- The petitioner must have presented every claim in the petition to the
state court first, and have pursued each claim all the way to the California
Supreme Court. This is called exhausting a claim. (There are some exceptions,
which are explained below.)
- The petition must be filed in federal court not later than one
year from the date that the California Supreme Court made its decision
(which will usually be the Supreme Court's decision to deny review of your
case, but in some cases will be the Supreme Court's decision made after it has
reviewed the decision of the Court of Appeal.) The clock stops running while a
state habeas corpus petition is pending in the state court. There are some
other exceptions to the one-year rule, which are explained below.
- Every claim in the petition must arise under federal law.
There are some exceptions to the rule that each claim must have been
presented in state court first. If the state doesn't have a process available
to hear the claim and correct the error complained of, you don't have to take
your claim to state court first. You are also excused from presenting your
claim in state court first if the state's process is ineffective to protect
your rights.
You normally get only one opportunity to raise a habeas
corpus claim in federal court. So if you file a petition for habeas corpus in
federal court and the petition is unsuccessful, you cannot make the same claim
in a new petition. Also, you should present all your claims in a single
petition. Sometimes you will not have exhausted all your claims in state court
at the same time. You should wait until they are all ready to go to federal
court.
You can present a second petition for habeas corpus, raising a
new claim, in two cases:
- when you are relying on a new rule of law that the Supreme Court has
made retroactive to cases in which the appeal was completed before the rule was
announced. You must file your claim within one year of the announcement of the
new rule.
- when you are relying on a factual basis that you could not have
discovered earlier and which enables you to prove by clear and convincing
evidence that no reasonable judge or jury could have found you guilty, if it
had not been for the unconstitutional error you are complaining about. You must
file the petition within one year of the time the new factual basis is
discovered (or would have been discovered if you had been diligent
enough.)
Appointment of Counsel for Indigent Petitioners
There is no constitutional right to the appointment of counsel for
habeas corpus petitions. By statute (28 USC
2254),
the federal court may appoint counsel for an indigent petitioner. Counsel
should be appointed if the court decides that the petition may have some merit
and that an evidentiary hearing is needed. The court will not appoint counsel
if it decides that the petition lacks merit.
How to File a Petition
A petitioner filing a petition for habeas
corpus on his own (called in pro. per. or per se) fills out a form that is
provided by the court. You will have to sign the petition under penalty of
perjury, so don't say anything that is not true. You can get a form by writing
to the federal court, or from a court's website (except for the Eastern
District). The websites are as follows:
Northern
District Click on forms.
Central District Click on
forms, then on civil forms.
Eastern
District Petition forms are not available at this site. Call
or write to the court, or use another court's form and change the district to
Eastern.
Southern
District Click on filing procedures, then forms, then civil.
You should file your petition in the District that contains the county you
were convicted in.
- Northern District:
Alameda, Contra Costa, Del Norte, Humboldt,
Lake, Marin, Mendocino, Monterey, Napa, San Benito, Santa Clara, Santa Cruz,
San Francisco, San Mateo, and Sonoma Counties.
- Central District:
Los Angeles, Orange, Riverside, San
Bernardino, San Luis Obispo, Santa Barbara and Ventura Counties.
- Eastern District, Fresno Division:
Calaveras, Fresno, Inyo,
Kern, Kings, Madera, Mariposa, Merced, Stanislaus, Tulare, and Tuolumne
Counties.
- Eastern District, Sacramento Division:
Alpine, Amador, Butte,
Colusa, El Dorado, Glenn, Lassen, Modoc, Mono, Nevada, Placer, Plumas,
Sacramento, San Joaquin, Shasta, Sierra, Siskiyou, Solano, Sutter, Tehama,
Trinity, Yolo, and Yuba Counties.
- Southern District:
San Diego and Imperial Counties.
You
must send a five dollar filing fee, unless you first obtain permission to file
in forma pauperis. Forms for filing in forma pauperis may be obtained from the
courts' websites (but not the Eastern District's) or by writing to the court.
You will need for a prison official to fill out the Certification section
stating how much money is in your account.
Mail the petition to the
appropriate address:
United States District Court, Northern District
450 Golden Ave, 16th Floor
San Francisco, CA 94102
Tel:
415-522-2000
United States District Court, Central District
312 N.
Spring St.
Los Angeles, CA 90012
Tel: 213-894-0289
United
States District Court, Eastern District
Fresno Division
1130 "O" St.,
Room 5000
Fresno, CA 93721
559-498-7483
United States District
Court, Eastern District
Sacramento Division
501 "I" St., Ste 4-200
Sacramento, CA 95814
Tel: 916-930-4000
United States District
Court, Southern District
880 Front ST., Rm. 4290
San Diego, CA 92101
Tel: 619-557-5600
Please send questions or comments to
factsla@sbcglobal.net.
Everything on this web site can be distributed to the general
public, reprinted, or reposted without permission of Families to Amend
California's 3-Strikes.
Date last modified: 1/29/01.