Dreher v. South Carolina, State of

CourtDistrict Court, D. South Carolina
DecidedFebruary 13, 2025
Docket0:24-cv-05952
StatusUnknown

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

Bluebook
Dreher v. South Carolina, State of, (D.S.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA

Davinne Shabaz Dreher, ) C/A No. 0:24-5952-CMC-PJG ) Petitioner, ) ) ORDER AND v. ) REPORT AND RECOMMENDATION ) Warden, Alvin S. Glenn Detention Center, ) ) Respondent. ) )

Petitioner Davinne Shabaz Dreher, a state pretrial detainee, filed this petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241. This matter is before the court pursuant to 28 U.S.C. § 636(b) and Local Civil Rule 73.02(B)(2)(c) (D.S.C.). Having reviewed the Petition in accordance with applicable law, the court concludes that it should be summarily dismissed.1 I. Factual and Procedural Background Petitioner is a pretrial detainee at the Alvin S. Glenn Detention Center awaiting trial on multiple charges.2 His Petition appears to concern the handling of his bond on those state charges. Petitioner does not state what relief he seeks, but indicates he needs copies of documents and his attorney is not helping. In addition to his Petition, Petitioner has sent several letters, some of which relate to the conditions of his confinement.

1 Petitioner has requested to proceed without prepaying the filing fee by filing a Form AO 240, which is construed as a motion for leave to proceed in forma pauperis. Based on a review of the motion, Petitioner’s request to proceed in forma pauperis is granted. (ECF No. 17.) 2 Petitioner has sixteen pending cases in the Richland County Court of General Sessions. See Richland County Fifth Judicial Circuit Public Index, https://publicindex.sccourts.org/Richland/PublicIndex/PISearch.aspx (last visited Feb. 6, 2025); Fusaro v. Cogan, 930 F.3d 241 n.1 (4th Cir. 2019) (finding courts may take judicial notice of a party’s court records); Colonial Penn Ins. Co. v. Coil, 887 F.2d 1236, 1239-40 (4th Cir. 1989) (same). II. Discussion A. Standard of Review Under established local procedure in this judicial district, a careful review has been made of the pro se petition filed in this case pursuant to the Rules Governing § 2254 Cases,3 28 U.S.C.

§ 2241; the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), Pub. L. No. 104- 132, 110 Stat. 1214; and in light of the following precedents: Denton v. Hernandez, 504 U.S. 25 (1992); Neitzke v. Williams, 490 U.S. 319, 324-25 (1989); Haines v. Kerner, 404 U.S. 519 (1972); Nasim v. Warden, Md. House of Corr., 64 F.3d 951 (4th Cir. 1995) (en banc); Todd v. Baskerville, 712 F.2d 70 (4th Cir. 1983). This court is required to liberally construe pro se pleadings, which are held to a less stringent standard than those drafted by attorneys. Erickson v. Pardus, 551 U.S. 89, 94 (2007); King v. Rubenstein, 825 F.3d 206, 214 (4th Cir. 2016). Nonetheless, the requirement of liberal construction does not mean that the court can ignore a clear failure in the pleading to allege facts which set forth a claim cognizable in a federal district court. See Weller v. Dep’t of Soc. Servs.,

901 F.2d 387 (4th Cir. 1990); see also Ashcroft v. Iqbal, 556 U.S. 662, 684 (2009) (outlining pleading requirements under Rule 8 of the Federal Rules of Civil Procedure for “all civil actions”).

3 The Rules Governing Section 2254 are applicable to habeas actions brought under § 2241. See Rule 1(b). B. Analysis Habeas corpus proceedings are the proper mechanism for a prisoner to challenge the legality or duration of his custody.4 See Preiser v. Rodriguez, 411 U.S. 475, 484 (1973). A petitioner that is detained on state charges may challenge his pretrial detention by filing a petition

for a writ of habeas corpus pursuant 28 U.S.C. § 2241. See In re Wright, 826 F.3d 774, 782-83 (4th Cir. 2016). However, in Younger v. Harris, 401 U.S. 37 (1971), the Supreme Court held that a federal court should not equitably interfere with state criminal proceedings except in the most narrow and extraordinary of circumstances. See Gilliam v. Foster, 75 F.3d 881, 903 (4th Cir. 1996). The Younger Court noted that courts of equity should not act unless the moving party has no adequate remedy at law and will suffer irreparable injury if denied equitable relief. Younger, 401 U.S. at 43-44 (citation omitted). From Younger and its progeny, the United States Court of Appeals for the Fourth Circuit has culled the following test to determine when abstention is appropriate: “(1) there are ongoing state judicial proceedings; (2) the proceedings implicate important state interests;

and (3) there is an adequate opportunity to raise federal claims in the state proceedings.” Martin Marietta Corp. v. Md. Comm’n on Human Relations, 38 F.3d 1392, 1396 (4th Cir. 1994) (citing Middlesex Cty. Ethics Comm’n v. Garden State Bar Ass’n, 457 U.S. 423, 432 (1982)). The first part of the test is satisfied in this case because Petitioner indicated he is currently detained on state criminal charges. The second part of the test is met because the Supreme Court has noted that “the States’ interest in administering their criminal justice systems free from federal

4 Petitioner’s subsequent challenges to his living conditions must be brought in a separate action pursuant to 42 U.S.C. § 1983. See Preiser v. Rodriguez, 411 U.S. 475, 499 (1973) (“[A section] 1983 action is a proper remedy for a state prisoner who is making a constitutional challenge to the conditions of his prison life, but not to the fact or length of his custody.”). interference is one of the most powerful of the considerations that should influence a court considering equitable types of relief.” Kelly v. Robinson, 479 U.S. 36, 49 (1986). The Court also addressed the third criterion in noting “that ordinarily a pending state prosecution provides the accused a fair and sufficient opportunity for vindication of federal constitutional rights.” Kugler v. Helfant, 421 U.S. 117, 124 (1975).

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Kugler v. Helfant
421 U.S. 117 (Supreme Court, 1975)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Kelly v. Robinson
479 U.S. 36 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
United States v. Edward Lester Schronce, Jr.
727 F.2d 91 (Fourth Circuit, 1984)
Adrian King, Jr. v. Jim Rubenstein
825 F.3d 206 (Fourth Circuit, 2016)
In Re: Terrence Wright v.
826 F.3d 774 (Fourth Circuit, 2016)
Dennis Fusaro v. Michael Cogan
930 F.3d 241 (Fourth Circuit, 2019)
Gilliam v. Foster
75 F.3d 881 (Fourth Circuit, 1996)

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