Bean v. Matteucci, No. 19-35119 (9th Cir. 2021)
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The Ninth Circuit reversed the district court's denial of a 28 U.S.C. 2241 habeas corpus petition where petitioner challenged an Oregon Circuit Court order under Sell v. United States, 539 U.S. 166 (2003), authorizing involuntary medication to restore petitioner's competency to stand trial for murder. The district court applied Younger abstention and concluded that intervention by a federal court would be inappropriate in light of the important state interests at stake in the pending criminal prosecution.
The panel held that the district court had subject matter jurisdiction and the authority to rule on the petition. In this case, the state mischaracterized the cognizability issue as a subject matter jurisdiction issue. Furthermore, although the basic Younger criteria are satisfied in this case, the irreparable harm exception to Younger applies and the district court erred in abstaining. The panel remanded for the district court to consider the issue of the cognizability of petitioner's claim in habeas.
Court Description: Habeas Corpus. The panel reversed the district court’s denial of Travis Leroy Bean’s 28 U.S.C. § 2241 habeas corpus petition, which challenged an Oregon Circuit Court order under Sell v. United States, 539 U.S. 166 (2003), authorizing involuntary medication to restore Bean’s competency to stand trial for murder; and remanded for further proceedings. Bean sought an order enjoining the Sell order on the grounds that his forcible medication, his custody at the Oregon State Hospital, and the state’s failure to provide an immediate mechanism for review of the Sell order violated his Fourteenth Amendment right to due process. The district court abstained under Younger v. Harris, 401 U.S. 37 (1971), determining that intervention by a federal court would be inappropriate given the important state interests at stake in the pending criminal prosecution. The panel wrote that, in asserting that Bean’s claim is not cognizable in habeas and that the district court therefore lacked subject-matter jurisdiction, the state mischaracterizes the cognizability question as a subject-matter jurisdiction issue. The panel wrote that the district court had subject- matter jurisdiction and the authority to rule on Bean’s petition, but rather than exercising its subject-matter jurisdiction, the district court abstained under Younger and BEAN V. MATTEUCCI 3 never reached the issue whether Bean’s claim is cognizable in habeas. The panel held that although the basic Younger criteria are satisfied, the irreparable harm exception to Younger applies in this case because the forcible administration of antipsychotic medications constitutes a particularly severe invasion of liberty and Bean’s right to avoid forcible administration of medications cannot be fully vindicated after trial. The panel concluded that the district court therefore erred in abstaining, and left the issue of cognizability of Bean’s claim in habeas for resolution by the district court. Dissenting, Judge Rawlinson wrote that the majority fails to analyze whether Bean’s claim falls “within the core of habeas as required” to establish jurisdiction under § 2241. She wrote that application of the principles set forth in Nettles v. Grounds, 830 F.3d 922 (9th Cir. 2016) (en banc), leads to the inescapable conclusion that Bean’s claim does not lie at the core of habeas corpus because there is no indication in the record that the injunction Bean seeks would terminate custody, accelerate release, or reduce the level of custody. Because the case was not properly brought as a habeas petition, Judge Rawlinson would remand it for the district court to determine if the case may be converted to a civil rights claim under 42 U.S.C. § 1983.
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