Edward Don Brown v. B. Cates

Summary

The United States District Court for the Eastern District of California placed and disregarded the petitioner’s letter concerning possible resentencing and continued incarceration in a closed habeas action. The court explained that any second or successive habeas petition requires authorization from the Ninth Circuit and directed the petitioner not to file further documents in the closed case.

Holdings

1. A second or successive federal habeas petition under 28 U.S.C. § 2254 may not be filed in the Eastern District of California unless the Ninth Circuit first authorizes the filing.
2. The letter was to be placed in the court file and disregarded, and Brown was directed not to file anything further in the closed case.

Questions Presented

1. Whether Brown could initiate or pursue a second or successive federal habeas petition in the Eastern District of California without prior authorization from the Ninth Circuit.
2. Whether Brown's June 5, 2025 letter should be treated as a permissible filing in the closed habeas action.

Disposition

other