in criminal cases involving misdemeanors when the defendant consents in writing to a trial before a magistrate. See 28 U.S.C. § 636(a); 18 U.S.C. § 3401. 3 . That subsection contains an identical limitation for "prisoner petitions challenging conditions of confinement.” We express no opinion on whether Reynaga’s action contained such a claim. Compare McCarthy v. Bronson, — U.S. -,-, 111 S.Ct. 1737, 1740, 114 L.Ed.2d 194 (1991) (noting evidence that "Congress intended [subsection (1)(B) ] to include in their entirety the two primary categories of suits brought by prisoners — applications for habeas corpus relief pursuant to 28 U.S.C. §§ 2254 and 2255 and actions for monetary or injunctive relief under 42 U.S.C. § 1983”) with Houghton v. Osborne, 834 F.2d 745, 749-50 (9th Cir. 1987) (<HOLDING>). 4 . Reynaga has already taken his case before
holding that a state university is not a person within the meaning of  1983 and therefore is not subject to suits brought under  1983 holding that a  1983 action based on the duration of a petitioners confinement must be dismissed unless that petitioner has first established the invalidity of the fact or length of that confinement holding that preclusion rules apply in section 1983 actions holding that  1983 action challenging jail clothing rules is not subject to subsection 1b and noting that the prison conditions covered by section 636b1b relate to the type of confinement and matters concerning health safety or punishment holding that denial of counsel in section 1983 action is not immediately appealable