Harold Hall v. Mark Arneson
Opinion
MEMORANDUM **
Plaintiff Harold C. Hall appeals the’ summary judgment entered in favor of Defendants Mark Arneson and Kenneth Crocker. Reviewing de novo, Ford v. City of Yakima, 706 F.3d 1188, 1192 (9th Cir. 2013) (per curiam), we affirm.
Hall’s claim that his confession was coerced is barred by the doctrine of issue preclusion. The state trial court reached its decision in Hall’s criminal case — finding that his confession was knowing, intelligent, and voluntary — after a full and fair process that involved a hearing, arguments, and a reasoned explanation of the answer. After Hall was convicted, he appealed to the California Supreme Court, which affirmed his judgment of conviction and thereby rejected the argument that his confession was coerced. This court later ordered that a writ of habeas corpus be granted, Hall v. Dir. of Corr. (Hall I), 343 F.3d 976, 985 (9th Cir. 2003) (per cu-riam), but on a completely different issue; no subsequent proceedings have concluded either that the trial court’s voluntary-confession decision was erroneous or that the court making the decision lacked jurisdiction or acted in some other fundamentally invalid way, see Hall v. City of Los Angeles (Hall III), 697 F.3d 1059 (9th Cir. 2012); Hall v. City of Los Angeles (Hall II), No. 07-56853, - Fed.Appx. -, 2009 WL 2020851 (9th Cir. July 13, 2009) (unpublished decision). Under California law, therefore, the trial court’s decision on vol-untariness was “final” because it was no longer subject to direct appeal. See People v. Sims, 32 Cal.3d 468, 186 Cal.Rptr. 77, 651 P.2d 321, 332 (1982) (defining finality under state law), superseded by statute on other grounds as stated in Gikas v. Zolin, 6 Cal.4th 841, 25 Cal.Rptr.2d 500, 863 P.2d 745, 751-52 (1993); People v. Cooper, 149 Cal.App.4th 500, 57 Cal.Rptr.3d 389, 405-06 (2007) (same). There is no unfairness in applying issue preclusion in these circumstances. See Lucido v. Superior Court, 51 Cal.3d 335, 272 Cal.Rptr. 767, 795 P.2d 1223, 1226-27 (1990) (looking to considerations of public policy before applying issue preclusion).
AFFIRMED.
This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3.
Reference
- Full Case Name
- Harold C. HALL, Plaintiff-Appellant, v. CITY OF LOS ANGELES, Defendant, and Mark Arneson, and Kenneth Crocker, Defendants-Appellees
- Cited By
- 1 case
- Status
- Unpublished