Baker v. Lancaster County District Court Adult Probation

CourtDistrict Court, D. Nebraska
DecidedOctober 30, 2024
Docket8:23-cv-00410
StatusUnknown

This text of Baker v. Lancaster County District Court Adult Probation (Baker v. Lancaster County District Court Adult Probation) is published on Counsel Stack Legal Research, covering District Court, D. Nebraska primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baker v. Lancaster County District Court Adult Probation, (D. Neb. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

BRIAN BAKER,

Petitioner, 8:23CV410

vs. MEMORANDUM AND ORDER LANCASTER COUNTY DISTRICT COURT ADULT PROBATION,

Respondent.

This matter is before the Court on initial review of Petitioner Brian Baker’s (“Petitioner”) Petition for Writ of Habeas Corpus filed pursuant to 28 U.S.C. § 2241. Filing No. 1. The Court conducts this initial review of the petition pursuant to 28 U.S.C. § 2243 and Rule 1(b) of the Rules Governing Section 2254 Cases in the United States District Courts which allows the Court to apply Rule 4 of those rules to a section 2241 action. For the reasons discussed below, the Court will dismiss the petition without prejudice. In his petition filed on September 18, 2023, Petitioner alleged he was serving a sentence of probation imposed by the Lancaster County District Court in case number CR21-190 and was awaiting a revocation hearing. Filing No. 1 at 1, 6. Petitioner sought to challenge both the revocation of his probation and the validity of his conviction alleging, inter alia, that he received ineffective assistance of counsel at trial and his probation officer lacked any grounds to file for revocation of Petitioner’s probation. Id. at 3, 7–8. As relief, Petitioner seeks to have his “probation completed . . . and the possession charge set aside.” Id. at 8. Petitioner’s state court records, available to this Court online, show that Petitioner’s probation was revoked and he was sentenced on December 20, 2023, to 270 days’ imprisonment with credit for 100 days already served. Subsequently, on February 14, 2024, the Lancaster County District Court dismissed Petitioner’s motion for postconviction relief as moot because Petitioner was discharged from serving his

sentence and released from custody on January 31, 2024.1 As the Eighth Circuit Court of Appeals has explained, “Article III of the United States Constitution limits the jurisdiction of the federal courts to actual, ongoing cases and controversies.” Haden v. Pelofsky, 212 F.3d 466, 469 (8th Cir.2000); see U.S. Const. art. III, § 2, cl. 1. “When, during the course of litigation, the issues presented in a case ‘lose their life because of the passage of time or a change in circumstances . . . and a federal court can no longer grant effective relief,’ the case is considered moot.” Id. (quoting Beck v. Mo. State High Sch. Activities Ass’n, 18 F.3d 604, 605 (8th Cir.1994) (alteration in original)); see also Spencer v. Kemna, 523 U.S. 1, 7, 118 S.Ct. 978, 140 L.Ed.2d 43 (1998) (stating an action becomes moot where it “no longer present[s] a case or controversy under Article III”). If an issue is moot in the Article III sense, we have no discretion and must dismiss the action for lack of jurisdiction. See Powell v. McCormack, 395 U.S. 486, 496 n. 7, 89 S.Ct. 1944, 23 L.Ed.2d 491 (1969).

Ali v. Cangemi, 419 F.3d 722, 723–24 (8th Cir. 2005). Because Petitioner’s probation was revoked and he has completely served his sentence, the Court concludes this case is moot and must be dismissed. See McGill v. Mukasey, No. 8:08CV345, 2009 WL 277556, at *1 (D. Neb. Feb. 5, 2009) (finding habeas petition moot where petitioner was released from custody, there was no

1 The Court takes judicial notice of the state district court records related to this case in State v. Brian J. Baker, No. CR21-190, District Court of Lancaster County, Nebraska. See Stutzka v. McCarville, 420 F.3d 757, 760 n.2 (8th Cir. 2005) (court may take judicial notice of judicial opinions and public records); Federal Rule of Evidence 201 (providing for judicial notice of adjudicative facts). Nebraska’s judicial records may be retrieved on-line through the JUSTICE site, https://www.nebraska.gov/justice/case.cgi. Relevant state court records are attached to this Memorandum and Order. continuing injury traceable to the respondents, and court could not issue any decision which would further the relief sought by the petitioner). Finally, because “the detention complained of arises from process issued by a state court,” Petitioner must obtain a certificate of appealability. See 28 U.S.C. § 2253; Fed. R. App. P. 22(b)(1); see also Hoffler v. Bezio, 726 F.3d 144, 153 (2d Cir. 2013) (collecting cases of courts that ruled a state prisoner who petitions for habeas relief under 28 U.S.C. § 2241 must obtain a certificate of appealability). The standards for certificates (1) where the district court reaches the merits or (2) where the district court rules on procedural grounds are set forth in Slack v. McDaniel, 529 U.S. 473, 484-85 (2000). The Court has applied the appropriate standard and determined that Petitioner is not entitled to a certificate of appealability. IT IS THEREFORE ORDERED that: 1. The petition for writ of habeas corpus, Filing No. 1, is dismissed without prejudice. No certificate of appealability has been or will be issued. 2. The Court will enter judgment by separate document.

Dated this 30th day of October, 2024.

BY THE COURT: Gs F Bhi ~

Joseph F. Bataillon Senior United States District Judge

Case Number: D02CR210000190 Transaction ID: 0020925377 IN THE DISTRICT COURT OF LANCASTER COUNTY |NEBRASKA'6 AM □

STATE OF NEBRASKA, ) Case No. CR 21-190 ) Plaintiff, ) ORDER OF SENTENCE ) VS. ) ) BRIAN J. BAKER, ) ) Defendant. )

Defendant present with counsel Matt Kosmicki. | Deputy County Attorney Chris Turner present. Neither the defendant nor defendant's attorney giving any reason why sentence should not now be pronounced, the court proceeded. to sentence the defendant. IT IS ORDERED that the original order of probation is revoked. The defendant be sentenced to an institution under the control of the Lancaster County Department of Corrections to a term of imprisonment of 270 days and ordered to

pay the costs of prosecution. The defendant was given credit for 100 days already served. Pursuant to Neb. Rev. Stat. § 29-2206(3), the costs of this action are to be deducted from the bond posted by the defendant to the extent that such bond is not otherwise encumbered by a valid lien, levy, execution, or assignment to counsel of record or to the person who posted the bond.

Any portion of this sentence may be served at hard labor, as provided by law.

No portion of this sentence may be served on house arrest. Commitment to issue. DATED: December 20, 2023.

BY THE COURT:

ECD) AIS, elson . D Judge

CERTIFICATE OF SERVICE

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Related

Powell v. McCormack
395 U.S. 486 (Supreme Court, 1969)
Spencer v. Kemna
523 U.S. 1 (Supreme Court, 1998)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Hoffler v. Bezio
726 F.3d 144 (Second Circuit, 2013)
State v. Styskal
493 N.W.2d 313 (Nebraska Supreme Court, 1992)
State v. York
770 N.W.2d 614 (Nebraska Supreme Court, 2009)
Tommy Joe Stutzka v. James P. McCarville
420 F.3d 757 (Eighth Circuit, 2005)

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Baker v. Lancaster County District Court Adult Probation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baker-v-lancaster-county-district-court-adult-probation-ned-2024.