Abdul-Sabur v. Department of Justice

CourtDistrict Court, W.D. Virginia
DecidedJanuary 17, 2025
Docket7:24-cv-00890
StatusUnknown

This text of Abdul-Sabur v. Department of Justice (Abdul-Sabur v. Department of Justice) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abdul-Sabur v. Department of Justice, (W.D. Va. 2025).

Opinion

FILED □ January 17, 2025 LAURA A. AUSTIN, CLERK IN THE UNITED STATES DISTRICT COURT sy: AB FOR THE WESTERN DISTRICT OF VIRGINIA st. Beeson ak ROANOKE DIVISION WAKEEL ABDUL-SABUR, ) Plaintiff, ) Case No. 7:24-cv-00890 ) v. ) ) By: Michael F. Urbanski DEPARTMENT OF JUSTICE, ) Senior United States District Judge Defendant. ) MEMORANDUM OPINION Plaintiff Wakeel Abdul-Sabur, proceeding pro se, is currently serving a state sentence in the custody of the Virginia Department of Corrections. He filed this civil rights action against the United States Department of Justice (DOJ) challenging the denial of his petition for commutation of a federal sentence. He also has filed a motion to seal the civil rights action. ECF No. 4. For the reasons set forth below, the complaint is DISMISSED for failure to state a claim upon which relief may be granted, and Abdul-Sabur’s motion to seal is DENIED. I. Background Abdul-Sabur is currently incarcerated at River North Correctional Center in Independence, Virginia. Compl., ECF No. 1, at 1. Upon the completion of his state sentence, he must serve a 46-month federal sentence imposed by another judge in this district. Mem. Supp. Compl., ECF No. 1-1, at 2; see also United States v. Abdul-Sabur, No. 6:99-cr-30073, 2023 WL 4400054, at *1 WW.D. Va. July 7, 2023) (summarizing the procedural history in the federal criminal case and noting that Abdul-Sabur is scheduled to be released from state custody in 2051).

Abdul-Sabur filed a petition for commutation of his federal sentence with the DOJ’s Office of the Pardon Attorney (Pardon Office). Id. He alleges that the Pardon Office determined that he was not eligible to have the sentence commutated “based upon a DOJ

regulation which provides that a defendant must have reported to a federal correctional facility and begun to serve the sentence” before seeking commutation.1 Id. Abdul-Sabur claims that the determination violated his federal constitutional rights to due process and equal protection. Id. He notes that “President Joe Biden gave his son Hunter Biden a full pardon before the imposition of the sentences for felony convictions” even though “Hunter Biden never reported to a federal correctional facility.” Id. Abdul-Sabur alleges that, by doing so, President

Biden “violated his own administration’s regulation.” Id. at 3. Abdul-Sabur seeks “declaratory and injunctive relief,” including the reinstatement of his commutation petition. Id. He also seeks “expedited review.” Id. II. Standard of Review The court is required to review a complaint in a civil action in which an inmate seeks redress from a governmental entity. 28 U.S.C. § 1915A(a). The court must “dismiss a

complaint, or any portion of the complaint, if the complaint . . . fails to state a claim upon which relief may be granted.” 28 U.S.C. § 1915A(b)(1). To survive dismissal for failure to state a claim, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell

1 Abdul-Sabur does not cite to a specific regulation in his complaint. It appears that he may be referring to § 9-140.113 of the DOJ’s Justice Manual. See U.S. Dep’t of Justice, Justice Manual § 9-140.113 (2018), available at https://www.justice.gov/jm/justice-manual (“Requests for commutation generally are not accepted unless and until a person has begun serving that sentence.”). Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id.

III. Discussion A. Claims Asserted in the Complaint Before turning to the claims presented by Abdul-Sabur, the court briefly summarizes the law applicable to federal clemency proceedings. The Constitution of the United States “bestows solely on the President the ‘Power to grant Reprieves and Pardons for Offences against the United States, except in Cases of Impeachment.’” Rosemond v. Hudgins, 92 F.4th

518, 525 (4th Cir. 2024) (quoting U.S. Const. art. II, § 2, cl. 2). “This clemency power means that the President can both pardon an underlying conviction or commute any part of a sentence.” Id. The President’s authority to grant clemency “may be exercised at any time after its commission, either before legal proceedings are taken, or during their pendency, or after conviction and judgment.” Id. (internal quotation marks omitted). The clemency power bestowed on the President is “not only expansive, but also

exclusive.” Id. It cannot be exercised or altered by Congress or the courts. Id. “Similarly, although modern Presidents have voluntarily channeled the exercise of their clemency power through the Pardon Office, that too does not create any constitutional limits on the ability to exercise that power or whether to use the Pardon Office at all.” Id. at 528. “As the relevant federal regulations acknowledge at the outset, they ‘are advisory only and for the internal guidance of Department of Justice personnel.’” Id. (quoting 28 C.F.R. § 1.11). The regulations

“create no enforceable rights in persons applying for executive clemency, nor do they restrict the authority granted to the President under Article II, section 2 of the Constitution.” 28 C.F.R. § 1.11. Ultimately, “[t]he President’s authority to grant clemency is unlimited, save for the

limits imposed by the Constitution.” Rosemond, 92 F.4th at 525. “So long as the President does not use the power to violate another provision of the Constitution, Congress and the Judiciary have no power to interfere with its exercise.” Andrews v. Warden, 958 F.3d 1072, 1076 (11th Cir. 2020); see also Ohio Adult Parole Auth. v. Woodard, 523 U.S. 272, 276 (1998) (“[P]ardon and commutation decisions have not traditionally been the business of courts; as such, they are rarely, if ever, appropriate subjects for judicial review.”) (internal quotation

marks omitted). Against this backdrop, the court turns to Adbul-Sabur’s claims for violations of his rights to due process and equal protection. 1. Due Process “The Due Process Clause of the Fifth Amendment requires the Government to provide due process of law before it deprives someone of ‘life, liberty, or property.’”2 Dep’t

of State v. Munoz, 602 U.S. 899, 910 (2024). “To state a procedural due process claim, a plaintiff must first identify a protected liberty or property interest and then demonstrate deprivation of that interest without due process of law.” Shaw v. Foreman, 59 F.4th 121, 127 (4th Cir. 2023) (internal quotation marks and brackets omitted).

2 Abdul-Sabur claims that he was deprived of due process and equal protection in violation of the Fourteenth Amendment. That amendment, however, “applies only to the states.” Bolling v. Sharpe, 347 U.S. 497, 499 (1954). Abdul-Sabur’s claim fails at the first step—he does not allege that he was deprived of any interest protected by the Due Process Clause.

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