Green v. Unknown Party

CourtDistrict Court, D. Arizona
DecidedMarch 13, 2025
Docket4:22-cv-00131
StatusUnknown

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

Bluebook
Green v. Unknown Party, (D. Ariz. 2025).

Opinion

1 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Jahmal Green, No. CV 22-131-TUC-JAS (LCK)

10 Petitioner, ORDER

11 v.

12 Warden of USP-Tucson,

13 Respondent. 14 15 DISCUSSION 16 As a threshold matter, the record reflects that after all the briefing, Report and 17 Recommendation, objections, and response thereto were completed in this case (see Docs. 18 1 through 22), the United States Supreme Court issued an opinion that impacts the issues 19 in this case. See Jones v. Hendrix, 599 U.S. 465 (2023). A review of the relevant record, 20 authority, and particularly Jones reflects that Jones forecloses any relief in this case for 21 Petitioner, and therefore Petitioner’s § 2241 Petition denied. See Jones, 599 U.S. 465, 476- 22 480 (2023) (“We now hold that the saving clause does not authorize such an end-run around 23 AEDPA. In § 2255(h), Congress enumerated two—and only two—conditions in which a 24 second or successive § 2255 motion may proceed. Because § 2255 is the ordinary vehicle 25 for a collateral attack on a federal sentence, the straightforward negative inference from § 26 2255(h) is that a second or successive collateral attack on a federal sentence is not 27 authorized unless one of those two conditions is satisfied . . . Even more directly, § 28 2255(h)(2)’s authorization of a successive collateral attack based on new rules ‘of 1 constitutional law’ implies that Congress did not authorize successive collateral attacks 2 based on new rules of nonconstitutional law. Had Congress wished to omit the word 3 ‘constitutional,’ it easily could have done so . . . Here, as often is the case, the best 4 interpretation is the straightforward one. Section 2255(h) specifies the two limited 5 conditions in which Congress has permitted federal prisoners to bring second or successive 6 collateral attacks on their sentences. The inability of a prisoner with a statutory claim to 7 satisfy those conditions does not mean that he can bring his claim in a habeas petition under 8 the saving clause. It means that he cannot bring it at all. Congress has chosen finality over 9 error correction in his case.”) (emphasis in the original). 10 In the alternative, assuming arguendo, that Jones did not impact the issues in this 11 case, the Court also agrees with the Report and Recommendation that Petitioner’s § 2241 12 Petition must be denied as discussed therein. The Court has reviewed the entire record in 13 this case (see Docs. 1 through 22) and the relevant legal authority bearing on this case. As 14 noted above, Petitioner filed objections to the Report and Recommendation and the 15 Government responded to those objections.1 16 As a threshold matter, as to any new evidence, arguments, and issues that were not 17 timely and properly raised before United States Magistrate Judge Kimmins, the Court 18 exercises its discretion to not consider those matters and considers them waived.2 See 19 United States v. Howell, 231 F.3d 615, 621-623 (9th Cir. 2000) (“[A] district court has 20 discretion, but is not required, to consider evidence presented for the first time in a party's

21 1 Unless otherwise noted by the Court, internal quotes and citations have been omitted when citing authority throughout this Order. 22 2 As a general matter, the Court notes that it has had numerous problems with parties in many cases attempting to raise new issues that could have been raised before the United 23 States Magistrate Judge. The Court does not abide such actions, and allowing such actions undermines the Court’s ability to properly manage the hundreds of cases pending before 24 the Court. See United States v. Ramos, 65 F.4th 427, 435 n. 5 (9th Cir. 2023) (“Ramos's motion for reconsideration argued that the district court failed to conduct de novo review 25 because the order adopting the report and recommendation stated that ‘as to any new ... arguments ... not timely ... raised before [the magistrate judge], the Court exercises its 26 discretion to not consider those matters and considers them waived” even though, according to Ramos, the case raised no waiver issue. But this argument misses the point. 27 The fact that the order contained extraneous language does not negate the district court's multiple assertions that it conducted de novo review and the magistrate judge's proper 28 analysis in recommending denial of the motion to suppress.”). 1 objection to a magistrate judge's recommendation . . . [I]n making a decision on whether 2 to consider newly offered evidence, the district court must . . . exercise its discretion . . . 3 [I]n providing for a de novo determination rather than de novo hearing, Congress intended 4 to permit whatever reliance a district judge, in the exercise of sound judicial discretion, 5 chose to place on a magistrate judge's proposed findings and recommendations . . . The 6 magistrate judge system was designed to alleviate the workload of district courts . . . To 7 require a district court to consider evidence not previously presented to the magistrate judge 8 would effectively nullify the magistrate judge's consideration of the matter and would not 9 help to relieve the workload of the district court. Systemic efficiencies would be frustrated 10 and the magistrate judge's role reduced to that of a mere dress rehearser if a party were 11 allowed to feint and weave at the initial hearing, and save its knockout punch for the second 12 round . . . Equally important, requiring the district court to hear evidence not previously 13 presented to the magistrate judge might encourage sandbagging. [I]t would be 14 fundamentally unfair to permit a litigant to set its case in motion before the magistrate, wait 15 to see which way the wind was blowing, and—having received an unfavorable 16 recommendation—shift gears before the district judge.”); United States v. Reyna-Tapia, 17 328 F.3d 1114, 1122 (9th Cir. 2003) (“Finally, it merits re-emphasis that the underlying 18 purpose of the Federal Magistrates Act is to improve the effective administration of 19 justice.”). 20 Assuming that there has been no waiver, the Court has conducted a de novo review 21 as to Petitioner’s objections. See 28 U.S.C. § 636(b)(1)(C) (“Within fourteen days after 22 being served with [the Report and Recommendation], any party may serve and file written 23 objections to such proposed findings and recommendations as provided by rules of court. 24 A judge of the court shall make a de novo determination of those portions of the report or 25 specified proposed findings or recommendations to which objection is made. A judge of 26 the court may accept, reject, or modify, in whole or in part, the findings or 27 recommendations made by the magistrate judge. The judge may also receive further 28 evidence or recommit the matter to the magistrate judge with instructions.”). 1 In addition to reviewing the Report and Recommendation and any objections and 2 responsive briefing thereto, the Court’s de novo review includes review of the record and 3 authority before United States Magistrate Judge Kimmins which led to the Report and 4 Recommendation in this case. 5 Upon de novo review of the record and pertinent authority, the Court finds 6 Petitioner’s objections to be without merit, rejects those objections, and adopts United 7 States Magistrate Judge Kimmins’ Report and Recommendation.

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Green v. Unknown Party, Counsel Stack Legal Research, https://law.counselstack.com/opinion/green-v-unknown-party-azd-2025.