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Andrews v. Lewis

Citation: 62 F. App'x 183Docket: No. 00-56282; D.C. No. CV-97-09187-NMM

Court: Court of Appeals for the Ninth Circuit; April 25, 2003; Federal Appellate Court

Narrative Opinion Summary

In this case, a California state prisoner, referred to as Andrews, appealed the denial of his habeas corpus petition under 28 U.S.C. § 2254, challenging his 28-years-to-life sentence for petty theft with a prior, imposed under California's three strikes law. The appeal fell within the jurisdiction of 28 U.S.C. § 2253. Andrews contended that his sentence amounted to cruel and unusual punishment in violation of the Eighth Amendment. However, the court relied on the Supreme Court precedents set in Lockyer v. Andrade and Ewing v. California, which uphold lengthy sentences under the three strikes law as not violative of the Eighth Amendment. The court concluded that the California courts' decision to affirm Andrews' sentence was not an unreasonable application of federal law, thus affirming the district court's denial of his habeas petition. The court also denied Andrews' motion for a broader certificate of appealability and dismissed the appellee's motion for summary affirmance as moot. The decision was deemed unsuitable for publication or citation, reflecting its reliance on established legal principles rather than novel interpretations.

Legal Issues Addressed

Cruel and Unusual Punishment under Eighth Amendment

Application: The court applies established Supreme Court precedent to determine that the sentence is not cruel and unusual punishment under the Eighth Amendment.

Reasoning: The Supreme Court's rulings in Lockyer v. Andrade and Ewing v. California establish that such sentences under California's three strikes law do not violate the Eighth Amendment.

Federal Review of State Court Decisions

Application: Federal intervention is limited to objectively unreasonable decisions, as emphasized by existing case law.

Reasoning: The court references Woodford v. Visciotti, emphasizing that federal intervention in state court decisions is warranted only when a decision is objectively unreasonable.

Habeas Corpus under 28 U.S.C. § 2254

Application: The court affirms the denial of the habeas corpus petition, finding no unreasonable application of federal law by the California courts.

Reasoning: Consequently, the court finds that the California courts' affirmation of Andrews' sentence was not an unreasonable application of federal law, leading to the proper denial of his petition by the district court.