Crayton v. Feazell

• Court: District Court, District of Columbia
• Decided: April 17, 2023
• Docket: Civil Action No. 2023-0633
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LEE D. CRAYTON, ) ) Petitioner, ) ) v. ) Civil Action No. 1:23-cv-00633 (UNA) ) MICHAEL FEAZELL, et al., ) ) Respondents. )

MEMORANDUM OPINION

This matter is before the court on its initial review of petitioner’s pro se petition for habeas

corpus relief pursuant to 28 U.S.C. § 2241, ECF No. 1, and application for leave to proceed in

forma pauperis, ECF No. 2. Petitioner’s in forma pauperis application will be granted and his

petition will be dismissed without prejudice for lack of jurisdiction. See Fed. R. Civ. P. 12(h)(3).

Petitioner is a state inmate currently incarcerated at the Telford Unit, located in New

Boston, Texas. The petition is far from a model of clarity. It appears that he was indicted and

tried in a Dallas County criminal court and that, according to the petitioner’s version of events, he

was either ultimately acquitted or has served out the resulting sentence and remains in custody due

to a pending detainer. He alleges that his present incarceration is violative of several federal

statutes and of his constitutional rights, and he demands his immediate release.

Petitioner faces insurmountable hurdles. First, a petitioner’s “immediate custodian” is the

proper respondent in a § 2241 habeas corpus action. See Rumsfield v. Padilla, 542 U.S. 426, 434–

35 (2004); see also Blair-Bey v. Quick, 151 F.3d 1036, 1039 (D.C. Cir. 1998) (“[T]he appropriate

defendant in a habeas action is the custodian of the prisoner.”) (citing Chatman-Bey v. Thornburg,

864 F. 2d 804, 810 (D.C. Cir. 1988) (en banc)). Petitioner has indeed sued his custodian, but “a district court may not entertain a habeas petition involving present physical custody unless the

respondent custodian is within its territorial jurisdiction,” Stokes v. U.S. Parole Comm’n, 374 F.3d

1235, 1239 (D.C. Cir. 2004); see Day v. Trump, 860 F.3d 686, 691 (D.C. Cir. 2017) (affirming

dismissal for want of jurisdiction where the District of Columbia was not “the district of residence

of [petitioner’s] immediate custodian for purposes of § 2241 habeas relief”). Therefore, petitioner

must file for such relief against his present custodian in the United States District Court for the

Eastern District of Texas. See id.; see also Robertson v. Merola, 895 F. Supp. 1, 5 (D.D.C. 1995)

(dismissing plaintiff’s claims for, inter alia, violation of his Sixth Amendment rights, arising from

an alleged delay in processing his pending detainers, because this District was “without jurisdiction

to entertain any challenge to the fact or duration of Plaintiff's confinement as such claims are within

the exclusive province of habeas corpus and would therefore have to be brought in the jurisdiction

encompassing the place of confinement.”).

Second, this court lacks jurisdiction to review the actions of the court that issued the

detainer, see Fleming v. United States, 847 F. Supp. 170, 172 (D.D.C. 1994) (following District of

Columbia Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983); Rooker v. Fidelity Trust Co.,

263 U.S. 413, 415, 416 (1923)), particularly because the applicable proceedings are considered

“active,” and this court may not violate the fundamental policy against federal interference with

ongoing state criminal prosecutions. Younger v. Harris, 401 U.S. 37, 46. (1971); see also 28 U.S.C.

§ 2244(d)(1)(a), (d)(2). Thus, petitioner must attempt to file for relief regarding the alleged

outstanding detainer in the issuing court. See Ciacci v. Hogan, 2012 WL 2501027, at *1 (D.D.C.

June 22, 2012) (collecting cases and dismissing plaintiff’s claims based on the Younger abstention

doctrine where plaintiff alleged that his Sixth Amendment right to speedy trial was violated because he had “yet to appear in court on [a] warrant[.]”), appeal dismissed, No. 12–5224, 2012

WL 5896801 (D.C. Cir. Oct. 31, 2012).

For these reasons, this habeas action is dismissed without prejudice for want of jurisdiction.

A separate order accompanies this memorandum opinion.

Date: April 17, 2023

Tanya S. Chutkan TANYA S. CHUTKAN United States District Judge