Gore v. Louthan

CourtDistrict Court, E.D. Oklahoma
DecidedJune 10, 2022
Docket6:22-cv-00064
StatusUnknown

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

Bluebook
Gore v. Louthan, (E.D. Okla. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA GLEN D. GORE, ) ) Petitioner, ) ) v. ) No. 22-CV-064-RAW-JAR ) DAVID LOUTHAN, Warden, and ) KERRY L. PETTINGILL, ) United States Marshal for the ) Eastern District of Oklahoma, ) ) Respondents. ) OPINION AND ORDER Before the Court is Petitioner Glen D. Gore’s Motion to Preliminarily Enjoin Respondents from Executing the State Detainer in Violation of the Laws, Treaties, and Constitution of the United States (Dkt. 28). The following history is pertinent to this habeas corpus action. On June 23, 2006, Petitioner was convicted in Pontotoc County District Court Case No. CF-2001-126 for the first degree murder of Debra Carter in 1982, and he was sentenced to life imprisonment without the possibility of parole (Dkt. 2 at 5, 9). On November 9, 2006, Petitioner filed a state application for post-conviction relief, requesting a direct appeal out of time. See Oklahoma State Courts Network at www.oscn.net.1 The trial court denied the request, and on March 26, 2007, the Oklahoma Court of Criminal Appeals (OCCA) declined 1 The Court takes judicial notice of the public records of the Oklahoma State Courts Network at http://www.oscn.net. See Pace v. Addison, No. CIV-14-0750-HE, 2014 WL 5780744, at *1 n.1 (W.D. Okla. Nov. 5, 2014). jurisdiction over his attempted appeal in Case No. PC-2007-53 (Dkt. 2 at 5-6; see also OSCN).

On September 23, 2020, Petitioner filed in the trial court a pro se application for post- conviction relief, alleging that pursuant to McGirt v. Oklahoma, __ U.S. __, 140 U.S. 2452 (2020), the state courts lacked prosecutorial authority over his crime (Dkt. 2-2 at 2). The trial court granted the application on March 17, 2021 (Dkt. 2-3). On March 22, 2021, a criminal complaint was filed in this Court’s Case No. 21-CR-

119-DCJ, alleging that Petitioner had committed the crime of Murder in Indian Country, and on March 29, 2021, he was arrested by the United States Marshals Service (USMS) at his state facility in Stringtown, Oklahoma.2 Also on March 29, 2021, the Oklahoma Department of Corrections issued a

detainer/hold on Petitioner, asking that the Department of Corrections be contacted prior to Petitioner’s release from custody (Dkt. 2-1). The detainer states: “Be advised that this serves as a hold/detainer on the above subject for the Oklahoma Department of Corrections. Prior to release from your custody please contact the Oklahoma Department of Corrections . . . .

If you transfer this subject to another jurisdiction, please forward this detainer and contact our office.” (Dkt. 2-1). On April 16, 2021, the United States Attorney for the Eastern District of Oklahoma

2 See United States v. Ahidley, 486 F.3d 1184, 1192 n.5 (10th Cir.) (exercising discretion “to take judicial notice of publicly-filed records in our court and certain other courts concerning matters that bear directly upon the disposition of the case at hand”), cert. denied, 552 U.S. 969 (2007). 2 obtained an indictment against Petitioner for the murder of Debra Carter in Indian Country and for the murder of Debra Carter in the perpetration of rape in Indian Country. See Case

No. 21-CR-119-DCJ. On September 10, 2021, the OCCA reversed the state district court’s post-conviction decision in Case No. PC-2021-244, based on the OCCA’s holding in State ex rel. Matloff v. Wallace, 497 P.3d 686 (Okla. Crim. App. 2021), which held that McGirt does not apply to a conviction that was final when McGirt was decided (Dkt. 2-6). In accordance with the

OCCA’s decision, the state district court reinstated Gore’s Judgment and Sentence that had been entered on June 23, 2006. See OSCN. On December 9, 2021, Petitioner filed a petition for a writ of certiorari in the United States Supreme Court directed to the question of whether McGirt applies retroactively to convictions that were final when McGirt was decided (Dkt.

2-9). The Supreme Court denied Petitioner’s petition in Gore v. Oklahoma, No. 21-883, 142 S.Ct. 1120, 2022 WL 515947 (Feb. 22, 2022) (Dkt. 2-10). On February 23, 2022, Petitioner filed through counsel this petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241 (Dkt. 2), raising two claims for relief:

Ground One: The reinstatement of Petitioner’s state conviction and the detainer are unlawful under the Constitution, treaties, and laws of the United States, because Oklahoma courts lack jurisdiction over the case. Ground Two: The state of Oklahoma surrendered any claim of jurisdiction over Petitioner Gore by (a) failing to timely object to the enforcement of the writ of habeas corpus issued by the state trial court; and/or (b) by the failing to perfect a timely appeal of that ruling. Id. at 23-26. 3 On April 18, 2022, Petitioner filed in this habeas case the aforementioned motion for a preliminary injunction (Dkt. 28). He alleges he “is an Indian unlawfully convicted of a

crime that occurred in Indian County by an Oklahoma state court that, under the Constitution, treaties, and laws of the United States, lacked jurisdiction to try him.” Id. at 2. Petitioner also claims that with his state murder conviction vacated, there was no basis to lodge the detainer. Id. at 7. He asks this Court “to quash the Oklahoma detainer, declare any future custody by the

Oklahoma Department of Corrections and the state of Oklahoma illegal, and declare the state of Oklahoma courts are without jurisdiction to reinstate Mr. Gore’s conviction for the 1982 murder of Ms. Carter within the territorial bounds of the Chickasaw Nation.” Id. at 5. He further requests this Court to “enjoin the USMS and state of Oklahoma from taking any

action on the unlawful detainer until this Court decides whether to grant a writ of habeas corpus.” Id. “An injunction is a drastic and extraordinary remedy, which should not be granted as a matter of course.” Monsanto Co. v. Geertson Seed Farms, 561 U.S. 139, 165 (2010)

(citation omitted). Further, to be entitled to injunctive relief, the movant must establish a violation of his constitutional rights. Rizzo v. Goode, 423 U.S. 362, 377 (1976) (citation omitted). The district court may grant a preliminary injunction if the party seeking it shows that “four equitable factors weigh in favor of the injunction.” Westar Energy v. Lake, 552 F.3d

4 1215, 1224 (10th Cir. 2009). The factors are (1) a substantial likelihood of prevailing on the merits; (2) irreparable harm in the absence of the injunction; (3) proof that the threatened

harm outweighs any damage the injunction may cause to the party opposing it; and (4) that the injunction, if issued, will not be adverse to the public interest. Id. Three types of preliminary injunctions are disfavored: (1) preliminary injunctions altering the status quo, (2) mandatory preliminary injunctions, and (3) preliminary injunctions granting the moving party all the relief it could recover at the conclusion of a full trial on the merits. These injunctions require strong showings of the likelihood of success on the merits and the balance of harms. Id. (citations omitted). Petitioner argues he is likely to succeed on the merits of this habeas petition, because his future custody under the terms of the detainer is illegal. He contends he is in the primary custody of federal officials to answer to his indictment, and the state of Oklahoma relinquished custody to the USMS pursuant to a valid arrest warrant after the state trial court granted a writ of habeas corpus.

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Related

Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Monsanto Co. v. Geertson Seed Farms
561 U.S. 139 (Supreme Court, 2010)
United States v. Ahidley
486 F.3d 1184 (Tenth Circuit, 2007)
Triplet v. Franklin
365 F. App'x 86 (Tenth Circuit, 2010)
Daniels v. United States
532 U.S. 374 (Supreme Court, 2001)
STATE ex rel. MATLOFF v. WALLACE
2021 OK CR 21 (Court of Criminal Appeals of Oklahoma, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
Gore v. Louthan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gore-v-louthan-oked-2022.