Knight v. Ahlin, No. 10-56211 (9th Cir. 2013)
Annotate this CaseThe state filed a civil petition against petitioner under the Sexually Violent Predator Act (SVPA), Cal. Welf. & Inst. Code 6600 et seq., just before petitioner's confinement was expected to end. Petitioner subsequently filed a pro se habeas corpus petition in the Superior Court, claiming that his exceedingly lengthy detention violated his constitutional rights. However, that court denied the petition and the California appellate courts agreed. Meanwhile, petitioner remained in custody and his SVPA petition made no progress. Petitioner then filed a federal pro se habeas petition. The district court concluded that the doctrine of Younger abstention applied and dismissed petitioner's case. The court held that the district court's abstention and denial of the writ were inappropriate where the state's counsel indicated that a trial on the commitment petition could be completed within 90 days and that the state would not oppose an order granting an alternative writ of habeas corpus. Therefore, the court reversed and remanded with instructions to the district court to grant a conditional writ of habeas corpus.
Court Description: Habeas Corpus. The panel reversed the district court’s denial of a 28 U.S.C. § 2241 habeas corpus petition by a California state prisoner challenging his detention pending a civil commitment proceeding under the Sexually Violent Predators Act (SVPA). Knight was convicted of rape and sentenced to 20 years. Before his expected release in 2004, the state filed a SVPA petition and the superior court ordered that petitioner Knight remain in custody while awaiting trial. After challenging his detention in state court, Knight filed his federal petition, which the district court denied under the Younger abstention doctrine. The panel held that Younger does not apply because the proceedings are not “ongoing.” The panel remanded with instructions that the district court grant a conditional writ requiring that Knight be tried within 90 days or released and the SVPA petition dismissed.
The court issued a subsequent related opinion or order on May 21, 2013.
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