Background
Mitchell Pyles petitioned under 28 U.S.C. § 2254 for a writ of habeas corpus, naming Cynthia Rojas, Warden, as respondent. A United States magistrate judge issued a Report and Recommendation on September 15, 2026. Objections were due October 5, but none were received by that deadline. On October 15, the district court accepted the magistrate judge's findings, conclusions, and recommendations and entered judgment dismissing the action without prejudice. The amended order identifies the governing defect as Pyles's failure to exhaust available state-court remedies under § 2254(b)(1)(A).
The Clerk's Office received three more motions from Pyles on October 14, and they were entered on the docket October 22. His renewed stay-and-abeyance motion repeated his contention that the state prosecution lacked constitutional authority after California repealed former Article VI, section 20 of its constitution in 1966. He attributed his late response to the July 20 Order to Show Cause to two deaths, drug overdoses at his correctional institution, and an inoperable law-library copying machine. He also sought an evidentiary hearing based on what he called contrived state-court factual findings.
Pyles's third motion asked the court to approve a proposed settlement agreement. Its requested relief included destruction of records establishing his federal and state convictions, two payments of $50,000, and a $200 million certified check. Those requests were part of his motion, not relief the court granted. The amended order addresses all three filings, their possible treatment as objections to the Report and Recommendation, and the effect of the existing judgment.
The Court’s Holding
The court again concluded that a stay and abeyance was unwarranted. Applying Rhines v. Weber, 544 U.S. 269 (2005), and Mena v. Long, 813 F.3d 907 (9th Cir. 2016), it identified the requirements of good cause for failing to exhaust state remedies, potentially meritorious claims, and an absence of intentionally dilatory tactics. Pyles's explanations might account for his delayed response to the Order to Show Cause, but they did not establish good cause for filing the federal petition before exhausting state remedies. He acknowledged that his sole claim remained unexhausted and did not show that state remedies were unavailable. The hearing and settlement-approval motions did not address any relevant issue in the recommendation.
To the extent the three motions could be construed as objections, the court conducted de novo review of the objected-to portions of the Report and Recommendation under 28 U.S.C. § 636(b)(1). It found that Pyles's arguments did not undermine the magistrate judge's findings or conclusions and overruled the objections. The September 15 recommendation therefore remained accepted and adopted, and the court declined to alter its earlier decision.
The operative rulings kept the petition dismissed without prejudice for failure to exhaust available state-court remedies. Pyles's original stay-and-abeyance motion remained denied, and his motion to enforce the repealed constitutional provision remained denied as moot. The court denied the renewed stay motion, the evidentiary-hearing motion, and the settlement-approval motion, overruling each to the extent it constituted objections. It expressly ordered that the October 15 judgment dismissing the action without prejudice remain in effect and directed service of the amended order.
Key Takeaways
- Explaining a late response to an Order to Show Cause is not the same as establishing good cause for failing to exhaust state remedies before filing a federal habeas petition.
- The court applied the Rhines framework and relied on Pyles's acknowledgment that his sole claim remained unexhausted and his failure to show that state remedies were unavailable.
- The court reviewed the three later motions de novo only to the extent they could be construed as objections, then overruled them because they did not undermine the recommendation.
- The renewed stay, evidentiary-hearing, and settlement-approval motions were denied, while the earlier stay motion remained denied and the constitutional-enforcement motion remained denied as moot.
- This was an amended order maintaining the existing disposition: the October 15, 2026 judgment of dismissal without prejudice remained in effect.
Why It Matters
The order distinguishes two different timing problems. Circumstances that might explain why a petitioner missed a response deadline do not necessarily explain why he filed a federal habeas petition without first exhausting state-court remedies. That distinction drove the renewed denial of stay and abeyance, alongside the admitted unexhausted status of the sole claim.
The ruling also shows how a district court can address post-recommendation filings both on their own merits and as possible objections. The hearing and settlement requests did not engage the recommendation's relevant issues, and de novo review produced no change. Because the dismissal remained without prejudice and the prior judgment remained effective, the amended order maintained rather than replaced the existing outcome.