Dunn v. Kansas, State of

District Court, D. Kansas·Decided October 10, 2023·No. 5:23-cv-03199·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

DRAKE A. DUNN,

Petitioner,

v. CASE NO. 23-3199-JWL

STATE OF KANSAS, et. al,

Respondents.

MEMORANDUM AND ORDER This matter is a petition for habeas corpus filed under 28 U.S.C. § 2241. Petitioner, a pretrial detainee at the Sedgwick County Jail in Wichita, Kansas, proceeds pro se. The Court screened the Petition (Docs. 1, 3) under Rule 4 of the Rules Governing Habeas Corpus Cases, foll. 28 U.S.C. § 2254, and entered a Memorandum and Order to Show Cause (Doc. 6) (“MOSC”) directing Petitioner to show good cause, in writing, why this matter should not be dismissed under the abstention doctrines set forth in Younger v. Harris, 401 U.S. 37 (1971), and Ex Parte Royall, 117 U.S. 241 (1886). This matter is before the Court on Petitioner’s response (Docs. 7, 10). I. § 2241 Petition Petitioner alleges that he is challenging Case No. 22-CR-419 pending in the District Court of Sedgwick County, Kansas. (Doc. 1, at 2.) As Ground One, Petitioner alleges a speedy trial violation, stating that he asserted his right to a speedy trial on July 6, 2022. Id. at 6. As Ground Two, Petitioner asserts that the state district court judge presiding over his criminal proceedings should recuse due to prejudice. Id. As Ground Three, Petitioner asserts that the time credit from municipal court has been miscalculated and his “appeal has been avoided.”1 Id. Petitioner’s request for relief in his Petition seeks “dismissal of [his] current trial” and states that the Petition is

1 The Court noted in the MOSC that Petitioner acknowledges that he has not had a trial yet in his criminal case, so it is unclear what sentence he is seeking to credit with the time served. Petitioner does not clarify this in his response to the MOSC. a “follow-up for case #22-3245-JWL-JPO.” Id. at 7. II. Younger and Ex Parte Royall Abstention Doctrines A. Ex Parte Royall The Court found in the MOSC that although “Younger and Ex Parte Royall are related doctrines” the Tenth Circuit has stated that Younger “addressed a federal court’s equitable power

to issue an injunction enjoining state proceedings” while Ex Parte Royall “involved a request for habeas relief.” Kirk v. Oklahoma, 2021 WL 5111985, at *2 (10th Cir. Nov. 3, 2021) (unpublished). In finding that Ex Parte Royall provided “more specific authority for the dismissal,” the Tenth Circuit held that: In Ex Parte Royall, the Supreme Court held that federal courts have habeas corpus jurisdiction to discharge a state-court pretrial detainee from custody on the basis that his detention violates the constitution. But the Court further concluded that a federal court should not exercise its discretion to exert that power except in very limited circumstances and should instead allow the state court to pass upon constitutional questions in the first instance. Acknowledging exceptions to this rule, the Court pointed to ‘cases of urgency[ ] involving the authority and operations of the [federal] government [or] the obligations of this country or its relations with foreign nations.’ The Supreme Court has also sanctioned federal habeas relief in a pretrial case where, rather than seeking to litigate a federal defense to a criminal charge, the habeas applicant sought to compel the state to bring him to trial. ‘[O]nly in the most unusual circumstances is a defendant entitled to have federal interposition by way of injunction or habeas corpus until after the jury comes in, judgment has been appealed from and the case concluded in the state courts.’ Id.

Kirk, 2021 WL 5111985, at *2 (internal citations omitted). The Tenth Circuit concluded that the district court did not err by abstaining from interfering in petitioner’s state-court criminal proceedings because “[h]is is not a ‘case[ ] of urgency’ involving the imposition of state custody for commission of an act done in pursuance of federal law or under the authority of a foreign state . . . [n]or is he seeking to compel the state to bring him to trial.” Id. B. Younger Under Younger, federal courts must abstain when “(1) the state proceedings are ongoing; (2) the state proceedings implicate important state interests; and (3) the state proceedings afford an adequate opportunity to present the federal constitutional challenges.” Phelps v. Hamilton, 122 F.3d 885, 889 (10th Cir. 1997) (citing Middlesex County Ethics Comm. v. Garden State Bar Ass’n,

457 U.S. 423, 432 (1982)). When Younger’s three requirements are met, abstention is mandatory unless one of three exceptions applies: the prosecution was “(1) commenced in bad faith or to harass, (2) based on a flagrantly and patently unconstitutional statute, or (3) related to any other such extraordinary circumstance creating a threat of ‘irreparable injury’ both great and immediate.” Winn v. Cook, 945 F.3d 1253, 1258–59 (10th Cir. 2019) (quoting Phelps v. Hamilton, 59 F.3d 1058, 1063–64 (10th Cir. 1995)). III. Exceptions to Abstention A. Relations with Foreign Nations

The Court found in the MOSC that Petitioner does not allege that the state is detaining him for committing an act done in pursuance of federal law or under the authority of a foreign government. In his response, Petitioner argues that he meets the limited circumstances in which intervention in state pre-trial proceedings is an exception to abstention. He claims that if his motion to consolidate (Doc. 8) is granted, it will show “that the Petitioner is in fact being held for alleged criminal acts done as required by federal law; is held in custody of the State under such acts allegedly done under the authority of a foreign country (see warrant #W22014—Hold for Other Agency—Augusta); and this matter is urgent and involves the United States’ relations with foreign nations.” (Doc. 10, at 1–2.) Petitioner’s motion to consolidate this habeas action with a closed civil rights case has already been denied by the Court. (Doc. 9.) Petitioner merely alleges that his state court criminal proceedings are urgent and involve the United States’ relations with foreign nations. Petitioner provides no support for this allegation and does not suggest how his criminal proceedings, which relate to his state domestic relations cases, involve relations with foreign

nations. B. Harassment Petitioner also argues that “[t]he State has in fact shown conduct of harassment, and the State law or regulation to be applied in this matter is in fact flagrantly and patently violative of express constitutional prohibitions as well.” (Doc. 10, at 2.) In support of his argument, Petitioner has submitted “Exhibit E,” a Waiver of Counsel, which Petitioner claims “shows the stipulations the trial court would require a defendant to represent himself.” (Doc. 10, at 2; Doc. 7, at 2.) Petitioner then argues that his pro se motions were denied by the state court judge because Petitioner was not entitled to dual representation and “needs to have appointed counsel file

motions.” (Doc. 10, at 3.) Petitioner has failed to meet his heavy burden to show his prosecution was commenced in bad faith or to harass.

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

Dunn v. Kansas, State of, (D. Kan. 2023).

Dunn v. Kansas, State of (Dunn v. Kansas, State of) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Ex Parte Royall
117 U.S. 241 (Supreme Court, 1886)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Braden v. 30th Judicial Circuit Court of Kentucky
410 U.S. 484 (Supreme Court, 1973)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Phelps v. Hamilton
122 F.3d 885 (Tenth Circuit, 1997)
Montez v. McKinna
208 F.3d 862 (Tenth Circuit, 2000)
Rivers v. King
23 F. App'x 905 (Tenth Circuit, 2001)
United States v. Simon Sandoval-De Lao
283 F. App'x 621 (Tenth Circuit, 2008)
United States v. Odell Bennett
539 F.2d 45 (Tenth Circuit, 1976)
Johnny Dickerson v. State of Louisiana
816 F.2d 220 (Fifth Circuit, 1987)
James Capps v. George Sullivan
13 F.3d 350 (Tenth Circuit, 1993)
United States v. E. Lavay McKinley
58 F.3d 1475 (Tenth Circuit, 1995)
Blaurock v. State of Kansas
686 F. App'x 597 (Tenth Circuit, 2017)
Winn v. Cook
945 F.3d 1253 (Tenth Circuit, 2019)
United States v. Castellon
218 F. App'x 775 (Tenth Circuit, 2007)