Derrick Jenkins v. Attorney General, State of Florida

CourtCourt of Appeals for the Eleventh Circuit
DecidedJune 6, 2024
Docket23-12794
StatusUnpublished

This text of Derrick Jenkins v. Attorney General, State of Florida (Derrick Jenkins v. Attorney General, State of Florida) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Derrick Jenkins v. Attorney General, State of Florida, (11th Cir. 2024).

Opinion

USCA11 Case: 23-12794 Document: 25-1 Date Filed: 06/06/2024 Page: 1 of 8

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 23-12794 Non-Argument Calendar ____________________

DERRICK TYRONE JENKINS, Petitioner-Appellant, versus ATTORNEY GENERAL, STATE OF FLORIDA,

Respondent-Appellee.

Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 9:23-cv-80034-RLR ____________________ USCA11 Case: 23-12794 Document: 25-1 Date Filed: 06/06/2024 Page: 2 of 8

2 Opinion of the Court 23-12794

Before WILSON, LUCK, and BLACK, Circuit Judges. PER CURIAM: Derrick Jenkins appeals the district court’s order adopting in part the magistrate judge’s report and recommendation and dis- missing his 28 U.S.C. § 2254 habeas corpus petition for lack of ju- risdiction. Jenkins asserts the district court erred by dismissing his § 2254 petition because, although the sentence of the conviction he was seeking to challenge had expired, he still satisfied the “in cus- tody” requirement under an exception stated by the Supreme Court in Lackawanna Cnty. Dist. Att’y v. Coss, 532 U.S. 394 (2001). Alternatively, he contends he is eligible for relief from his convic- tion under the writs of error coram nobis and audita querela. I. 28 U.S.C. § 2254 A habeas corpus petition filed under § 2254 challenging a state court conviction may only be considered when the petitioner is “in custody pursuant to the judgment of a State court.” 28 U.S.C. § 2254(a). We have construed the custody requirement “very liber- ally . . . and it is by now well-settled the ‘use of habeas corpus is not restricted to situations in which the applicant is in actual, physical custody.’” Howard v. Warden, 776 F.3d 772, 775 (11th Cir. 2015) (al- terations omitted) (quoting Jones v. Cunningham, 371 U.S. 236, 239 (1963)). “Even in light of this broad interpretation given to the phrase in custody, the term still requires that the state exercise some control over the petitioner.” Id. (quotation marks omitted). USCA11 Case: 23-12794 Document: 25-1 Date Filed: 06/06/2024 Page: 3 of 8

23-12794 Opinion of the Court 3

The district court did not err when it found Jenkins failed to meet the “in custody” requirement and when it dismissed his § 2254 petition for lack of jurisdiction. See Diaz v. State of Fla. Fourth Jud. Cir. ex rel. Duval Cnty., 683 F.3d 1261, 1263 (11th Cir. 2012) (explain- ing the finding a petitioner is not “in custody” for purposes of § 2254(a) is a jurisdictional question reviewed de novo). Although this Court construes this requirement “very liberally,” the restraints Jenkins received as a result of his contempt conviction were insuf- ficient. See Howard, 776 F.3d at 775. The restraints Jenkins asserts constituted custody were col- lateral consequences of his expired conviction, which the Supreme Court explained are insufficient to satisfy the requirement. The Court explained in Maleng v. Cook that it had never held “a habeas petitioner may be ‘in custody’ under a conviction when the sen- tence imposed for that conviction has fully expired at the time his petition is filed.” 490 U.S. 488, 491 (1989) (emphasis in original). It added, “once the sentence imposed for a conviction has completely expired, the collateral consequences of that conviction are not themselves sufficient to render an individual ‘in custody’ for the purposes of a habeas attack upon it.” Id. at 492. Jenkins’ restrictions on filing documents or making commu- nications are distinct from and less burdensome than other re- straints the Supreme Court and our Court have identified. In Jones, the Supreme Court held a defendant who was placed on parole was “in custody.” 371 U.S. at 241-42. It reasoned the conditions and restrictions of parole constituted custody because “they USCA11 Case: 23-12794 Document: 25-1 Date Filed: 06/06/2024 Page: 4 of 8

4 Opinion of the Court 23-12794

significantly restrain[ed] [the] petitioner’s liberty to do those things which in this country free men are entitled to do.” Id. at 242-43. The conditions the petitioner faced because of his parole included the requirements he live in a specific place; his parole could be re- voked or modified at any time; he could be arrested and returned to prison for cause; he obtain permission to leave the community, change residence, or own a car; and he make monthly reports to a parole office. Id. at 237. Conversely, in Clements v. Florida, we held Florida sex of- fender registration requirements did not constitute a restraint on liberty sufficient to meet the “in custody” requirement. 59 F.4th 1204, 1216-17 (11th Cir. 2023). We concluded that, although the registration and reporting requirements were “demanding and not the sort of obligations and restraints ‘shared by the public gener- ally,’” they were still “less oppressive in terms of personal liberty than the restraints faced by the parolee in Jones” or those described in other cases in which the Supreme Court found nonincarcerated individuals were in custody, such as “persons released on personal recognizance bonds” and “noncitizens subject to deportation and under supervision.” Id. at 1215. We justified our conclusion be- cause the petitioner was “not at the beck and call of state officials,” was “not required to live in a certain community or home,” did “not need permission to hold a job or drive a car,” and, although he was required to provide in-person notice when he was leaving the state and country, he did not need the permission of state officials to make the trips. Id. USCA11 Case: 23-12794 Document: 25-1 Date Filed: 06/06/2024 Page: 5 of 8

23-12794 Opinion of the Court 5

Moreover, there is no caselaw to support Jenkins’ contention that restrictions on constitutionally protected speech could consti- tute a sufficiently significant restraint on liberty to rise to the level of custody, especially considering the fact this Court has held even more intrusive and restrictive conditions did not satisfy the require- ment. See Clements, 59 F.4th at 1215-17. Because Jenkins was no longer “in custody,” the district court did not have jurisdiction over his § 2254 petition. See 28 U.S.C. § 2254. And Jenkins has failed to show that an exception to the custody requirement applied or even existed. Jenkins’ reliance on the plurality in Lackawanna is inapt for two reasons. First, the ac- tual-innocence exception described by Justice O’Connor was sepa- rate from the majority opinion’s discussion of the custody require- ment. See Lackawanna Cnty. Dist. Att’y, 532 U.S. at 401-06. The Court concluded the petitioner in that case satisfied the custody requirement because he was incarcerated based on a sentence that had been enhanced by the expired conviction that he was seeking to challenge. See id. at 401-02.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Michael J. Peter
310 F.3d 709 (Eleventh Circuit, 2002)
United States v. Gary William Holt
417 F.3d 1172 (Eleventh Circuit, 2005)
Jones v. Cunningham
371 U.S. 236 (Supreme Court, 1963)
Maleng v. Cook
490 U.S. 488 (Supreme Court, 1989)
United States v. Denedo
556 U.S. 904 (Supreme Court, 2009)
Henry William Theriault v. State of Mississippi
390 F.2d 657 (Fifth Circuit, 1968)
Larry Bonner v. City of Prichard, Alabama
661 F.2d 1206 (Eleventh Circuit, 1981)
Ruben Diaz v. State of Florida Fourth Judicial Circuit
683 F.3d 1261 (Eleventh Circuit, 2012)
Lackawanna County District Attorney v. Coss
532 U.S. 394 (Supreme Court, 2001)
Roderick Howard v. Warden
776 F.3d 772 (Eleventh Circuit, 2015)
Louis Matthew Clements v. State of Florida
59 F.4th 1204 (Eleventh Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Derrick Jenkins v. Attorney General, State of Florida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/derrick-jenkins-v-attorney-general-state-of-florida-ca11-2024.