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Brown v. Mayle

Citation: 66 F. App'x 136Docket: No. 99-17261, 99-56197; D.C. No. CV-99-00241-WBS, CV-98-04672-R-BQR

Court: Court of Appeals for the Ninth Circuit; June 6, 2003; Federal Appellate Court

Narrative Opinion Summary

The United States Supreme Court vacated the Ninth Circuit's prior decision and remanded the case, instructing further proceedings in light of Mayle v. Brown. The case involved challenges to California's Three Strikes Law, which the Court dismissed by referencing recent decisions in Lockyer v. Andrade and Ewing v. California. The appellants, Bray and Brown, raised issues related to the Three Strikes Law, with Brown bringing additional claims. The district court's decision was affirmed, noting that Brown did not establish a prima facie case of unequal application under McQuery v. Blodgett. Additionally, Brown's request for resentencing was found ineligible for federal habeas review, based on Williams v. Borg. The court also ruled that the application of the Three Strikes Law did not violate the Ex Post Facto Clause, as the law was enacted prior to Brown's offense, supported by United States v. Sorenson and United States v. Ahumada-Avalos. The court's memorandum emphasized that the disposition is not suitable for publication, adhering to Ninth Circuit Rule 36-3, and affirmed all district court decisions.

Legal Issues Addressed

Application of California's Three Strikes Law

Application: The Supreme Court rejected petitions against the Three Strikes Law following precedents established in Lockyer v. Andrade and Ewing v. California.

Reasoning: The court rejected petitions challenging California's Three Strikes Law in light of recent Supreme Court cases, specifically Lockyer v. Andrade and Ewing v. California.

Ex Post Facto Clause Violation

Application: The court held that the Three Strikes Law, effective before Brown's offense, did not violate the Ex Post Facto Clause.

Reasoning: It was held that since the Three Strikes Law became effective in March 1998, prior to Brown's offense, there was no violation of the Ex Post Facto Clause, referencing United States v. Sorenson and United States v. Ahumada-Avalos.

Federal Habeas Review Eligibility

Application: Brown's request for resentencing under People v. Superior Court was deemed ineligible for federal habeas review.

Reasoning: The district court correctly determined that Brown's request for resentencing under People v. Superior Court (Romero) was not eligible for federal habeas review, citing Williams v. Borg.

Prima Facie Case of Unequal Application

Application: The court found that Brown did not meet the burden of establishing a prima facie case for unequal application of the Three Strikes Law.

Reasoning: The court affirmed the district court's finding that Brown failed to establish a prima facie case of unequal application of the Three Strikes Law, as per McQuery v. Blodgett.