Gonzales v. CDC

When a state habeas hearing provides a “full and fair hearing” for the issue to be heard and determined under federal standards, the district court must apply issue preclusion to a 42 U.S.C. § 1983 habeas action.

Ricky Gonzales, serving an enhanced sentence for his conviction of two counts of attempted murder and assault with a firearm, appealed from the district court’s dismissal, as claim precluded, of his 42 U.S.C. § 1983 habeas action, as well as the court’s denial of his request to amend his complaint to add an Eighth Amendment challenge against the “debriefing” procedures in relation to his confinement in the Secured Housing Unit. The issue for the Ninth Circuit was whether a state court decision on a prisoner’s habeas corpus petition precludes any claims under federal law. Adhering to the Federal Full Faith and Credit statute, 28 U.S.C. § 1738, which requires federal courts to “give to a state-court judgment the same preclusive effect as would be given that judgment under the law of the State in which the judgment was rendered,” the panel held that the district court properly applied the claim-preclusive effect, barring nineteen of Gonzales’s twenty causes of action. The panel found that California’s state habeas hearing provided a “full and fair hearing” for the issue to be heard and determined under federal standards. Thus, issue preclusion must be applied. Additionally, however, the panel held that the district court erred by dismissing, for lack of standing, Gonzales’s Eighth Amendment challenge to the debriefing process. Construing his complaint liberally, the panel held that Gonzales’s complaint contained an alleged attempt to debrief, and found this sufficient to establish standing. AFFIRMED in part, REVERSED in part, and REMANDED.