Sanchez Valle v. Barron
- Proceeding
- district
- Area
- civil
- Panel
- Andrew G. Schopler (author)
Analysis
The court reviewed a 28 U.S.C. § 2241 habeas petition filed by a federal prisoner seeking a transfer closer to his home and relief from alleged medical neglect. The court dismissed the petition for lack of jurisdiction, holding that the First Step Act bars judicial review of prison designations and that conditions of confinement must be raised in a § 1983 action.
| What the court decided | The model |
|---|---|
Dismissal of the habeas petition for lack of jurisdiction“Sanchez Valle’s habeas petition is DISMISSED for lack of jurisdiction.” | agree with court The court correctly identified that 18 U.S.C. § 3621(b)(5) explicitly states that designations of places of imprisonment are not reviewable by any court, thereby stripping the district court of subject matter jurisdiction over the transfer request. Furthermore, the court correctly applied the well-established principle that habeas corpus is not the proper vehicle for challenging conditions of confinement, which are properly addressed through 42 U.S.C. § 1983 actions. The dismissal is legally sound based on the statutory text and controlling circuit precedent. |
The order itself: sound — The order is concise and directly addresses the two distinct claims in the petition. It correctly cites the statutory bar on judicial review of prison designations and the procedural requirement that conditions of confinement be litigated via § 1983 rather than habeas corpus. The reasoning is legally accurate and supported by the cited authorities.
Opinion
1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF CALIFORNIA 3 Francisco SANCHEZ VALLE, Case No.: 23-cv-1446-AGS-DEB 4 Petitioner, ORDER DENYING HABEAS PETITION (ECF 1) 5 v. 6 Howard C. BARRON, 7 Respondent. 8 9 In this 28 U.S.C. § 2241 habeas petition, petitioner seeks a prison transfer and relief 10 from the allegedly onerous conditions of his confinement. These issues cannot be addressed 11 through the requested writ of habeas corpus. 12 A. Prison Transfer 13 Petitioner Francisco Sanchez Valle is imprisoned over 1,200 miles from his primary 14 residence in California and seeks a transfer closer to home. (Id.) He believes the First Step 15 Act “states that I have to be less than 500 miles away from my home.” (Id. at 12.) He’s 16 mistaken. 17 The First Step Act does not mandate that prisoners be placed within 500 miles of 18 their primary residence. Instead of such a bright-line rule, the Act sets forth a multi-factor 19 analysis to ensure that inmates are placed “as close as practicable to the prisoner’s primary 20 residence, and to the extent practicable, in a facility within 500 driving miles of that 21 residence.” 18 U.S.C. § 3621(b) (emphasis added). 22 More importantly, by the Act’s own terms, “a designation of a place of imprisonment 23 under this subsection is not reviewable by any court.” Id. § 3621(b)(5). In other words, the 24 statute that Sanchez relies upon forbids this Court from reviewing his prison designation, 25 let alone ordering his transfer to another facility. See Ahmad v. Jacquez, 860 F. App’x 459, 26 461–62 (9th Cir. 2021) (upholding dismissal of § 2241 petition seeking a prison transfer 27 under the First Step Act because under “§ 3621(b), we lack jurisdiction”). 28 1 ||B. Conditions of Confinement 2 Sanchez Valle also complains that he “has not seen an appropriate doctor,” is “afraid 3 || that lack of medical care will lead to the return of [his] cancer,” and is repeatedly ignored 4 ||by prison staff who “never respond” to him. (ECF 1, at 6, 9-11.) Claims regarding prison 5 || conditions cannot be raised in a habeas petition. See Nettles v. Grounds, 830 F.3d 922, 927 6 ||(9th Cir. 2016). Requests for relief from the “circumstances of confinement may be 7 || presented in a [42 U.S.C.] § 1983 [civil-rights] action.” ! Jd. 8 CONCLUSION 9 Sanchez Valle’s habeas petition is DISMISSED for lack of jurisdiction. The Clerk 10 |} will close this case. 11 ||Dated: September 14, 2023 12 13 Andrew G. Schopler United States District Judge 14 15 16 17 18 19 20 21 22 23 24 25 6 ' Even if this were a § 1983 action, it would be in the wrong venue. Such cases must be filed where the defendants “‘reside[]’” or “a substantial part of the events or omissions 27 || giving rise to the claim occurred.” See DeBose v. Madden, No. 20-cv-1132-MMA (WVG), 28 2021 WL 689049, at *2 n.2 (S.D. Cal. Feb. 23, 2021). Sanchez Valle is confined at Federal Detention Center, SeaTac, in Seattle, Washington. (ECF 1, at 1.)