Griffin v. Gomez, et al., No. 09-16744 (9th Cir. 2014)
Annotate this CaseBecause of petitioner's gang activities, he had been confined for many years to a security housing unit (SHU), to protect other prisoners from him and his gang underlings. This appeal addressed the enforcement of orders regarding petitioner's conditions of confinement. In 2006, because petitioner claimed that he was no longer an active gang member, the district court ordered him released from the SHU. Petitioner was then returned to the SHU based on allegations of gang activity. The district court subsequently issued orders in 2009 and 2011 enforcing its 2006 order to release petitioner. The court concluded that, in the circumstances of this case, the district court abused its discretion by finding violations of its 2006 order in 2009 and 2011. Accordingly, the court concluded that prison officials did not violate the 2006 order. The court concluded, however, that the 2009 and 2011 orders must be vacated as an abuse of discretion where they improperly impeded state prison management. Accordingly, the court remanded with directions to dismiss the 2009 and 2011 orders.
Court Description: Habeas Corpus. The panel vacated and reversed, for abuse of discretion, the district court’s 2009 and 2011 orders enforcing its initial 2006 order releasing petitioner from the Security Housing Unit. Petitioner was validated as an Aryan Brotherhood member in 1979 and put into the SHU at a prison in the California prison system. He claimed that he was no longer an active gang member and in 2006, the district court ordered him released from the SHU. At the time, petitioner was not in the SHU because he had been released into federal confinement as a defendant in a federal RICO case. When he was returned to state custody, he was placed in the Administrative Segregation Unit pending an investigation of his gang status. Based on his conviction in the RICO case, which in turn was based on allegations of gang activity during a period when petitioner claimed he was no longer a gang member, prison officials concluded that petitioner was still an active member and again housed him in the SHU. During this time, the district court issued orders in 2009 and 2011 enforcing its 2006 order to release petitioner from the SHU. Assuming the validity of the unchallenged 2006 order, the panel held that the district court abused its discretion in issuing the 2009 and 2011 orders, because prison officials did not violate the 2006 order, the order did not amount to a continuing injunction, and the order did not say that petitioner could not subsequently earn his way back to the SHU. The panel further explained that the challenged orders must be vacated for an independent and alternative reason: the district court failed to take proper account of a line of Supreme Court authority limiting federal district court management of state prisons. Judge Berzon dissented because the only consideration that matters at this juncture is that California has never complied with the original release order, as construed by the court that issued it. She would affirm the 2009 and 2011 orders because the district court reasonably construed its 2006 order, which the state violated instead of seeking appellate review. She expressed no opinion on whether, having complied with the 2006 order, California could then revalidate petitioner as a gang member and send him back to segregated housing.
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