Unreported / Non-Citable
Background
Earnest Woods, a state inmate confined at San Quentin Rehabilitation Center, filed a pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254 in the Northern District of California concerning the denial of parole. On October 5, 2026, the court dismissed the petition for failure to state a cognizable claim for relief and entered judgment the same day. As described in the later order, Woods's petition claimed that the state appellate court erred in transferring his case to San Diego County, where he was convicted and sentenced, and described the claim as a challenge to the First Appellate Court's ruling transferring his appeal.
On October 30, 2026, Woods filed a motion for clarification and reconsideration. He contended the court had erred because its order read that the state appellate court erred in transferring his case to San Diego County, when, he said, the state court had not transferred his case anywhere under California Rules of Court, rule 8.385(c)(2). Because the motion was filed within twenty-eight days after entry of judgment, the court construed it as a motion to alter or amend the judgment under Federal Rule of Civil Procedure 59(e).
The Court’s Holding
The court denied the motion. It recited the Ninth Circuit rule that Rule 59(e) relief should not be granted, absent highly unusual circumstances, unless the court is presented with newly discovered evidence, committed clear error, or there is an intervening change in the law. Woods showed none of these: there was no intervening change in controlling law, he presented no newly discovered evidence, and the court found no clear error in dismissing the petition.
The court explained that Woods misread its earlier order. That order did not say the state appellate court erred in transferring the case. It said that Woods made that claim, and it cited his petition, in which he stated he was challenging the First Appellate Court's ruling to transfer his appeal. The court also explained that it referred to rule 8.385(c)(2) because the state appellate court's order denied his state habeas petition on that basis. The court therefore adhered to its earlier finding that the state appellate court properly denied the petition without prejudice so that Woods could proceed in the San Diego County Superior Court, which he admitted was the county of conviction.
The court added that motions for reconsideration should not be frequently made or freely granted and are not a substitute for appeal or a means of attacking a perceived error of the court. The order terminated the motion and stated that Woods may proceed with an appeal to the Ninth Circuit; it did not address any other relief.
Key Takeaways
- A reconsideration motion filed within twenty-eight days of a judgment dismissing a habeas petition is treated as a Rule 59(e) motion, and relief requires new evidence, clear error, or an intervening change in the law absent highly unusual circumstances.
- Disagreement based on a misreading of the court's own order does not show clear error; here the court pointed out that it had merely recorded the petitioner's own claim.
- The order reaffirmed that the state appellate court's denial of the state habeas petition without prejudice, under rule 8.385(c)(2), left Woods able to proceed in the San Diego County Superior Court.
- The order denies reconsideration only; it does not decide the merits of any parole-denial challenge beyond reaffirming the prior dismissal for failure to state a cognizable claim.
- The court expressly noted that Woods may proceed with an appeal to the Ninth Circuit, so appellate review of the dismissal remains open.
Why It Matters
This is a short, unpublished district court order applying settled Rule 59(e) standards, and it carries no precedential weight. Its value is as an example of how courts handle reconsideration motions from pro se petitioners who misread a dismissal order: the court identified the passage at issue, showed it described the petitioner's own allegation, and denied relief.
What remains open is limited. The order does not rule on the merits of the underlying parole denial or on whether any claim could be pursued in state court, and the earlier dismissal order is not before us except as quoted here. Any challenge to the dismissal and the denial of reconsideration must proceed on appeal to the Ninth Circuit, and the order does not address whether a certificate of appealability is required or should issue.