Opinion
Civil No. 02-574 ADM/JMM
June 18, 2002
MEMORANDUM OPINION AND ORDER
I. INTRODUCTION
This matter is before the undersigned United District Court Judge pursuant to Petitioner Arthur Dale Senty-Haugen's ("Petitioner") Objection [Doc. No. 9] to the April 24, 2000, Report and Recommendation ("R R") of United States Magistrate Judge John M. Mason [Doc. No. 8]. The R R recommends that Petitioner's application for habeas corpus relief be dismissed with prejudice. For the reasons set forth below, the R R is adopted in its entirety. The factual background of this matter is adequately set forth in the R R and is incorporated by references for the purposes of the present Objections.
Magistrate Judge Mason died on June 8, 2002 while this matter was pending before the assigned District Court Judge.
II. DISCUSSION
A. Standard of Review
A district court must make an independent, de novo evaluation of those portions of an R R to which objection is made and may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge. See 28 U.S.C. § 636(b)(1)(C); D. Minn. L.R. 72.1(c)(2).
B. Previous Petition
Petitioner has filed a Petition for Writ of Habeas Corpus ("Petition") under 28 U.S.C. § 2254 contending that the State of Minnesota has improperly denied him credit for the 509 days he spent in civil confinement at the Minnesota Sexual Psychopathic Personality Treatment Center ("MSPPTC") prior to his conviction [Doc. No. 1]. Petitioner suggests that the restrictive conditions of his bail release at the MSPPTC are legally indistinguishable from pre-sentencing custody in the county jail, entitling him to sentencing credit.
Petitioner commenced the present habeas corpus proceeding by listing seven grounds for relief. After a prior R R recommended summary dismissal, Petitioner abandoned his unexhausted claims [Doc. No. 5]. The four remaining grounds, with their numbers as assigned from the original petition, are: (2) the trial court set conditions of confinement that violated his constitutional rights; (3) the trial court violated his rights to due process and equal protection by subjecting him to unique conditions during his pre-trial confinement; (5) the trial court imposed excessive bail; and (7) the trial court committed a sentencing error by failing to give him proper credit for the time he was civilly confined before sentencing [Doc. No. 1].
C. Petitioner's Objections to the R R
Petitioner objects to the R R's recommended dismissal of his Petition. He contends that his second, third and fifth grounds for relief have a discernible relation to the correctness of the sentence imposed by the trial court. He also argues that his seventh ground for relief has a "constitutional dimension."
1. Second, Third and Fifth Grounds for Relief
In a habeas corpus proceeding, the federal court must determine the constitutionality of the sentence imposed. Petitioner's allegations about his pre-trial conditions have no discernible relationship to the correctness of the sentence he is now challenging. Judge Mason correctly determined that even if the pre-trial conditions of Petitioner's bail release were improper (although to conclude so seems very unlikely), it does not automatically follow that his sentence is unconstitutional.
Petitioner invokes King v. Wyrick, 516 F.2d 321 (8th Cir. 1975) in an attempt to demonstrate that the conditions of his pre-trial civil confinement were unconstitutional. Objections at 1. King, however, is distinguishable from the Petitioner's case. In King, the court determined that equal protection considerations arise when defendants who cannot afford bail receive no sentencing credit for pre-conviction jail time. King, 516 F.2d at 323. It is a violation of equal protection if an indigent defendant serves "a longer term in connection with the offense than would a wealthier prisoner who is sentenced to the same term but who is able to meet bail to avoid incarceration before trial and sentencing." Id. at 323.
In the present case, Petitioner did post bail. He was then returned to the MSPPTC, where he had been confined for several years prior to his arrest. In light of the fact that Petitioner obtained his release from the Carlton County Law Enforcement Center, his place of pre-trial confinement, King is not applicable, and no cognizable equal protection claim exists. Additionally, no due process issue exists because Petitioner's Objections do not offer any new arguments or legal authority in support of such claims.
In his fifth ground for relief, Petitioner contends that his bail was excessive, but offers no evidence in support of his position. Given the fact that he did secure bail, this claim appears misplaced.
However, even if he were unable to post bail, prisoners are entitled to habeas corpus relief for excessive bail only when the state court acted with "legal arbitrariness in the administration of the bail right provided." Mastrian v. Hedman, 326 F.2d 708, 711 (8th Cir. 1964), cert. denied, 376 U.S. 965 (1964). In determining the amount of bail, a federal court does not substitute its judgment for that of the state court's, unless the amount is "beyond the range within which judgments could rationally differ in relation to the apparent elements of the situation." Mastrian, 326 F.2d at 711. Petitioner made no showing in regard to the arbitrariness or the irrationality of the amount of bail set by the trial court; he merely labeled it as excessive.
The burden for establishing the right to relief lies with the prisoner. Summer v. Mata, 455 U.S. 591, 597 (1982); 28 U.S.C. § 2254(e)(1). Since Petitioner offers no logical argument nor cites any relevant legal authority in support of his claims, his second, third and fifth grounds for relief should be dismissed with prejudice.
2. Seventh Ground for Relief
In his seventh ground for relief, Petitioner alleges that the trial court committed an error in its sentencing by denying him credit for time spent in civil confinement at MSPPTC. This claim lacks a federal constitutional dimension; rather, it asks the federal court to engage in statutory interpretation of state laws. "It is not the province of a federal habeas corpus court to examine state-court determinations on state-law questions. In conducting habeas review, a federal court is limited to deciding whether a conviction violated the Constitution, law or treaties of the United States." Estelle v. McGuire, 502 U.S. 62, 67 (1991).
Petitioner mistakenly relies on Bostic v. Carlson, 884 F.2d 1267 (9th Cir. 1989), which involves due process and the awarding of Statutory Good Time credits for prisoners already incarcerated. Objections at 2; Bostic, 884 F.2d at 1270. These issues have no bearing on Petitioner's case.
In this instant case, there is no constitutional issue; the only question is whether the state court's interpretation of a sentencing statute is correct. A federal court may only intervene in a state judicial process to correct wrongs of a constitutional dimension. Wycott v. Nix, 869 F.2d 1111, 1113 (8th Cir. 1989). Determining whether a state court's interpretation of a state crediting statute is erroneous is not the duty of the federal court under habeas jurisdiction. Travis v. Lockhart, 925 F.2d 1095, 1097 (8th Cir. 1991). It would be an invasion of state autonomy if the federal court reinterpreted state sentencing statutes. Harkins v. Wyrick, 589 F.2d 387, 391 (8th Cir. 1979).
The federal Constitutional provides no guarantees for credit toward pre-sentencing confinement, except when defendants cannot afford to post bail. See King, 516 F.2d at 321. In the absence of a constitutional violation, Petitioner's seventh ground for relief is summarily dismissed with prejudice.
III. ORDER
Based upon the foregoing, and all the files, records, and proceedings herein, IT IS HEREBY ORDERED that:
1. The R R [Doc. No. 8] is ADOPTED; and
2. Petitioner's Writ of Habeas Corpus [Doc. No. 1] is DENIED and DISMISSED WITH PREJUDICE.
LET JUDGMENT BE ENTERED ACCORDINGLY.