Burpee v. Comal County Jail

CourtDistrict Court, W.D. Texas
DecidedJune 1, 2023
Docket1:23-cv-00565
StatusUnknown

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

Bluebook
Burpee v. Comal County Jail, (W.D. Tex. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

JOSEPH BURPEE, § Petitioner § § v. § A-23-CV-00565-DII-SH § COMAL COUNTY JAIL, § Defendant §

REPORT AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

TO: THE HONORABLE UNITED STATES DISTRICT COURT

Before this Court are Joseph Burpee’s Petition for Habeas Corpus under 28 U.S.C. § 2241 (Dkt. 1). The District Court referred this case to this Magistrate Judge for disposition of all non- dispositive pretrial matters and for findings and recommendations on all case-dispositive motions, pursuant to the District Court’s Standing Case Management Order, 28 U.S.C. § 636(b)(1), Federal Rule of Civil Procedure 72, and Rule 1 of Appendix C of the Local Rules of the United States District Court for the Western District of Texas. Dkt. 2. I. Background Petitioner Joseph Burpee is detained in Comal County Jail in New Braunfels, Texas, for a parole violation. Burpee is no stranger to this Court. While incarcerated, he has filed a plethora of civil actions and appeals that have been dismissed as frivolous or malicious or for failure to state a claim. See Burpee v. Martinez, 1:23-cv-412-LY, at Dkt. 4 (W.D. Tex. Apr. 18, 2023) (listing Burpee’s past cases and dismissing civil rights complaint with prejudice under three-dismissal rule of 28 U.S.C. § 1915(g)). In his instant Petition for Habeas Corpus under 28 U.S.C. § 2241, Burpee alleges that Comal County Sherriff Mark Reynolds “entrapped” him into paying a law enforcement officer $10,000. Dkt. 1 at 1.1 Burpee appears to ask that the District Court order his release from custody. II. Analysis A state pretrial detainee such as Burpee may challenge the authority of the state to bring him

to trial and the constitutionality or lawfulness of his present confinement by petition for writ of habeas corpus under § 2241. See Braden v. 30th Jud. Cir. Ct. of Kentucky, 410 U.S. 484, 489-90 (1973); Dickerson v. Louisiana, 816 F.2d 220, 224 (5th Cir. 1987). A state pretrial detainee may proceed under § 2241 if two requirements are satisfied. First, the petitioner must be in custody. See 28 U.S.C. § 2241(c); Dickerson, 816 F.2d at 224. Second, the petitioner must have exhausted his available state remedies. Id. As stated, Burpee is being detained at Comal County Jail and therefore is “in custody” for purposes of § 2241. But he also must show that he has exhausted his state administrative remedies. While § 2241 does not contain an exhaustion of state remedies requirement, it has long been settled that a § 2241 petitioner must exhaust available state court remedies before a federal court

will entertain a challenge to state detention. See Dickerson, 816 F.2d at 225. As the Fifth Circuit has explained: Despite the absence of an exhaustion requirement in the statutory language of section 2241(c)(3), a body of case law has developed holding that although section 2241 establishes jurisdiction in the federal courts to consider pretrial habeas corpus petitions, federal courts should abstain from the exercise of that jurisdiction if the issues raised in the petition may be resolved either by trial on the merits in the state court or by other state procedures available to the petitioner. Id.

1 The Court sua sponte GRANTS Burpee in forma pauperis status. See Burpee v. Hays Cnty., 1:22-cv-176- LY, at Dkt. 4 (W.D. Tex. March 9, 2022) (granting Burpee in forma pauperis status). Exceptions to the exhaustion requirement are appropriate where the available administrative remedies either are unavailable or wholly inappropriate to the relief sought, or where the attempt to exhaust such remedies would itself be a patently futile course of action. However, exceptions to the exhaustion requirement apply only in “extraordinary circumstances,” and [Burpee] bears the burden of demonstrating the futility of administrative review.. Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994) (per curiam) (citations omitted). Generally, the exhaustion requirement is satisfied only when the grounds urged in a federal petition were first fairly presented to the state’s highest court in a procedurally proper manner. Dupuy v. Butler, 837 F.2d 699, 702 (5th Cir. 1988). In Texas, this requires that the claims be presented to the Texas Court of Criminal Appeals through either a petition for discretionary review or postconviction writ of habeas corpus before a pretrial detainee may seek federal habeas corpus relief. Deters v. Collins, 985 F.2d 789, 795 (5th Cir. 1993). Burpee presents no evidence that he sought state habeas relief or otherwise presented the claims he raises in this federal habeas petition to any state court. Thus, he has not exhausted his state court remedies. Burpee has not shown that trial or existing state procedures, including pretrial habeas review, direct appeal, and post-trial state habeas review, are insufficient to protect his constitutional rights; nor has he argued, much less shown, any extraordinary circumstances warranting excusal from the exhaustion requirement. Accordingly, pretrial habeas interference by this Court in the normal functioning of the state’s criminal processes is not authorized, and Burpee has no right to seek federal habeas corpus relief now. Braden, 410 U.S. at 493. The Court recommends that Burpee’s Petition be dismissed without prejudice subject to his right to seek federal habeas corpus relief after the state proceedings are concluded. III. Recommendation For these reasons, the undersigned RECOMMENDS that the District Court DISMISS without prejudice Joseph Burpee’s Petition for Habeas Corpus under 28 U.S.C. § 2241 (Dkt. 1). IV. Certificate of Appealability An appeal may not be taken to the court of appeals from a final order in a habeas corpus proceeding “unless a circuit justice or judge issues a certificate of appealability.” 28 U.S.C. § 2253(c)(1)(A). Under Rule 11 of the Federal Rules Governing Section 2255 Proceedings, as amended, the district court must issue or deny a certificate of appealability (“COA”) when it enters

a final order adverse to the applicant. A COA may issue only if a petitioner has made a substantial showing of the denial of a constitutional right. 28 U.S.C. § 2253(c)(2). When a district court rejects a petitioner’s constitutional claims on the merits, “the petitioner must demonstrate that reasonable jurists would find the district court’s assessment of the constitutional claims debatable or wrong.” Slack v. McDaniel, 529 U.S.

Related

Fuller v. Rich
11 F.3d 61 (Fifth Circuit, 1994)
Braden v. 30th Judicial Circuit Court of Kentucky
410 U.S. 484 (Supreme Court, 1973)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Johnny Dickerson v. State of Louisiana
816 F.2d 220 (Fifth Circuit, 1987)
Bobby Battle v. U.S. Parole Commission
834 F.2d 419 (Fifth Circuit, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
Burpee v. Comal County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burpee-v-comal-county-jail-txwd-2023.