Whether the Central District of California's practice of allowing magistrate judges to issue orders with dispositive effects on habeas petitioners' rights violates Article III of the U.S. Constitution

QUESTION PRESENTED Pro se Petitioner Deshon Atkins filed his federal habeas petition months early and without first seeking state habeas review. Atkins withheld consent to magistrate jurisdiction. The magistrate judge, before the Warden even noticed an appearance, issued a sua sponte order deeming two of Atkins’ three claims unexhausted and providing Atkins four “choices” to remedy the error. Upon receipt of this order, Atkins withdrew the claims and proceeded on the Petition, which was subsequently denied. Magistrate jurisdiction is limited to the resolution of non-dispositive matters. 28 U.S.C. § 636; Fed. R. Civ. P. § 72; United States v. Raddatz, 447 U.S. 667, 673 (1980). Here, however, the magistrate pre-determined the issue of exhaustion without seeking district court review and issued an Order which led Atkins to abandon two claims. Is the practice of the Central District of California in allowing magistrate judges to issue generic orders in the habeas context that have a dispositive effect on Petitioners’ rights to judicial review consistent with federal law and the provisions of U.S. Const., Article III, as the Ninth Circuit held, or does this practice represent an unconstitutional delegation of Article III authority? i