Abdulhaseeb v. LNU

CourtDistrict Court, W.D. Oklahoma
DecidedAugust 18, 2022
Docket5:21-cv-01016
StatusUnknown

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

Bluebook
Abdulhaseeb v. LNU, (W.D. Okla. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

MADYUN ABDULHASEEB, ) ) Petitioner, ) ) vs. ) NO. CIV-21-1016-HE ) WILLIAM “CHRIS” RANKINS, Acting ) Warden ) ) Respondent. )

ORDER

Petitioner Madyun Abdulhaseeb,1 a state prisoner proceeding pro se, filed the present habeas petition pursuant to 28 U.S.C. § 2241. He challenges the Oklahoma Pardon and Parole Board’s (the “Board”) decision to deny him parole or at least the process by which the Board denied it. He seeks an order directing the Board to grant him a personal appearance before the Board and declaring that the Board’s application of certain statutes to him violate the Ex Post Facto Clause and/or was in impermissible bill of attainder. Pursuant to 28 U.S.C. § 636(b)(1)(B) and (C), the matter was referred to U.S. Magistrate Judge Suzanne Mitchell for initial proceedings. Thereafter, the respondent moved to dismiss the petition on various grounds. Judge Mitchell has now issued a Report and Recommendation which, though rejecting certain of the procedural arguments offered by respondent, recommends that the petition be dismissed on the merits. Petitioner has objected to virtually everything in the Report, including some aspects of it which were

1 Petitioner was convicted under the name Jerry Lewis Thomas but has apparently changed his name. favorable to him. His objections trigger de novo review of the matters to which objection has been made. Respondent did not object to the Report. Habeas review under § 2241 is available “if an individual is in custody in violation

of the Constitution or laws or treaties of the United States. The fundamental purpose of a § 2241 habeas proceeding is to allow a person in custody to attack the legality of that custody, and the traditional function of the writ is to secure release from custody.” Palma- Salazar v. Davis, 677 F.3d 1031, 1035 (10th Cir. 2012) (quotations and citations omitted). Here, petitioner does not seek immediate release from custody but instead challenges the

manner in which the Board has conducted his parole proceedings, essentially arguing that the duration of his custody is being extended as a result. The Report addressed the matter of the proper respondent in the case. Judge Mitchell applied the rule from Rumsfeld v. Padilla, 542 U.S. 426, 434 (2004) that the proper respondent to a habeas petition is the person who has custody over the petitioner

and, as a result, designated the warden of the facility where petitioner is held as the respondent. Petitioner objects to that on various grounds. If it were actually necessary to resolve the question here, the court would likely resolve it on the basis suggested in the Report. But it is not necessary.2 Appropriate state authorities have appeared and defended against the petition. Further, this court’s disposition of the petition, like the Magistrate

Judge’s ultimate recommendation, does not depend on the identity of the particular respondent. Largely as did the Magistrate Judge, the court concludes the most efficient

2 Similarly, petitioner objects to a number of other determinations by the Magistrate Judge which do not impact the ultimate disposition of the petition and therefore need not be resolved here. resolution of the present petition is to address it on the merits rather than getting bogged down in the intricacies of habeas theory and procedure. As the Report noted, petitioner appears to assert essentially three claims: He

contends (1) the procedures and standards applied by the Board in considering him for parole usurp the legislature’s right to establish standards, (2) that application to him of the standards in Oklahoma’s aging prisoner parole statute (and others) violate the constitutional prohibition on ex post facto laws and/or are an unconstitutional bill of attainder, and (3) that the Board’s failure to give him an in-person hearing was an abuse of

discretion. With respect to the “usurpation” argument, petitioner objects to the Report’s conclusions but offers no persuasive reason for doing so. To the extent his “usurpation” argument is something separate from the ex post facto argument, it appears to be grounded in some claimed violation of the Oklahoma Constitution — either that the “usurpation”

was a violation of separation of powers principles or that the Board was otherwise operating beyond its delegated powers. Either way, the claimed violation is grounded in state law rather than based on a violation of federal rights. As the Report correctly noted, claims of state law violations are not cognizable in a federal habeas action. Bullock v. Carver, 297 F.3d 1036, 1055 (10th Cir. 2002).

In Oklahoma, “[a] prisoner has no constitutionally protected claim to a release on parole before the expiration of his sentence.” Phillips v. Williams, 608 P.2d 1131, 1133 (Okla. 1980) (cert. denied Shabazz v. Williams, 449 U.S. 860 (1980)). The central thrust of petitioner’s argument, however, is that the application to him of the current version of the “aging prisoner statute”, 57 Okla. Stat. § 332.21, as well as other statutes, violates the Ex Post Facto Clause of the Constitution. Specifically, he asserts he was entitled to parole consideration under the "Forgotten Man Act”, 57 Okla. Stat. § 332.7 (1971) but, by reason

of § 332.21’s restriction on parole consideration for specific defined crimes, he is no longer eligible. As the Report correctly noted, the ex post facto clause generally prohibits retroactively criminalizing an act, increasing the punishment for a crime, or depriving the defendant of a defense that was formerly available to him. Collins v. Youngblood, 497 U.S. 37, 42 (1990). In the parole context, the clause has application only to the extent that

the changed law or rule being challenged produces more than a speculative risk of increasing the measure of punishment attached to the particular crime. The mere possibility of increasing the punishment is insufficient in the parole context. Henderson v. Scott, 260 F.3d 1213, 1216 (10th Cir. 2001) (citing Cal. Dept. of Corrections v. Morales, 514 U.S. 499 (1995) and other cases.)

Here, petitioner has offered no persuasive, non-speculative reason for concluding his punishment will be increased. To the extent petitioner’s arguments rests on the authority of the Board to grant him a parole, there has been no reduction of the Board’s authority. At the time of his conviction in 1981, the Board had no power to grant paroles at all. All it could do was recommend parole to the Governor. 57 Okla. Stat. § 332.7

(1971).3 As a result, any limitation on the Board’s power to grant paroles now does not represent any net “reduction” from what was in place at the time of petitioner’s conviction.

3 This provision was enacted in 1947 and is sometimes referred to as the “Forgotten Man” statute because it mandated that the Pardon and Parole Board consider eligibility for parole Petitioner argues that the application of Oklahoma’s “aging prisoner” statute, 57 Okla. Stat.

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Related

Nixon v. Administrator of General Services
433 U.S. 425 (Supreme Court, 1977)
Collins v. Youngblood
497 U.S. 37 (Supreme Court, 1990)
California Department of Corrections v. Morales
514 U.S. 499 (Supreme Court, 1995)
Rumsfeld v. Padilla
542 U.S. 426 (Supreme Court, 2004)
Henderson v. Scott
260 F.3d 1213 (Tenth Circuit, 2001)
Bullock v. Carver
297 F.3d 1036 (Tenth Circuit, 2002)
Palma-Salazar v. Davis
677 F.3d 1031 (Tenth Circuit, 2012)
Phillips v. Williams
1980 OK 25 (Supreme Court of Oklahoma, 1980)
Shirley v. Chestnut
603 F.2d 805 (Tenth Circuit, 1979)
Shabazz v. Williams
449 U.S. 860 (Supreme Court, 1980)

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Abdulhaseeb v. LNU, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abdulhaseeb-v-lnu-okwd-2022.