Hanson v. Quick

CourtDistrict Court, E.D. Oklahoma
DecidedMay 27, 2025
Docket6:25-cv-00081
StatusUnknown

This text of Hanson v. Quick (Hanson v. Quick) 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
Hanson v. Quick, (E.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA JOHN FITZGERALD HANSON, ) ) Petitioner, ) ) v. ) Case No. CIV-25-81-RAW-JAR ) CHRISTE QUICK, Warden, et al., ) ) Respondents. ) ORDER On May 8, 2025, Magistrate Judge Robertson filed Findings and Recommendation (#18), recommending that the relief sought by petitioner be denied and the motion to dismiss of the federal respondents be granted. Also, the recommendation was that petitioner’s request for a stay of execution be denied. Petitioner has filed objections (#20) and the Oklahoma respondents have responded (#21). The opening petition (#2) is titled “Petition for writ of habeas corpus pursuant to 28 U.S.C. §2241 and complaint for declaratory and injunctive relief.” To the extent the action comes under §2241, it was referred to the Magistrate Judge pursuant to Rule 8(b) of the Rules Governing Section 2254 Proceedings for the United States District Courts (made applicable to §2241 petitions under Rule 1(b)). To the extent the petition seeks injunctive relief, it was be referred for a recommended disposition pursuant to 28 U.S.C. §636(b)(1)(B). Both Rule 72(b)(3) F.R.Cv.P. and Rule 8(b) of the Section 2254 rules require the reviewing court to

determine de novo any part of the Magistrate Judge’s disposition that has been properly objected to. The undersigned has done so. Petitioner “was sentenced to life in federal prison for a series of federal crimes and later sentenced to death by the State of Oklahoma for

the carjacking, kidnapping, and murder of two Oklahomans.” Hanson v. Drummond, 2025 WL 636319, *1 (W.D.La.2025). Petitioner was serving his life sentence in a federal prison in Louisiana. “In 2022, pursuant to

18 U.S.C. §3623, the State of Oklahoma asked the BOP [Bureau of Prisons] to immediately transfer Hanson into state custody so Oklahoma could carry out its death sentence. The BOP refused to release Hanson based on the finding of the then Regional Director of BOP’s South Central

Regional Office, Heriberto H. Tellez, that Hanson’s transfer to state custody was not in the public interest.” Id. “In 2025, Oklahoma renewed its request for Petitioner’s transfer.” (#18 at 8). “[O]n February 28, 2025, Acting BOP Director Lothrop

approved the transfer. On the night of March 1, 2025, Petitioner was transferred to Oklahoma State Penitentiary.” Id. at 9.

2 Section 3623 provides: “The Director of the Bureau of Prisons shall order that a prisoner who has been charged in an indictment or

information with, or convicted of, a State felony, be transferred to an official detention facility within such State prior to his release from a Federal prison facility if – (1) the transfer has been requested by the Governor or other executive authority of the State; (2) the State has

presented to the Director a certified copy of the indictment, information, or judgment of conviction; and (3) the Director finds that the transfer would be in the public interest.”

The Magistrate Judge found that all three required conditions are satisfied in the present case. (#18 at 13-14). Petitioner does not dispute this finding, but rather contends that the Findings and Recommendation does not give meaning to the phrase “prior to his release.”

“In our American system of dual sovereignty, each sovereign – whether the Federal Government or a State – is responsible for ‘the administration of [its own] criminal justice syste[m].’” Setser v. United States, 566 U.S. 231, 241 (2012)(quoting Oregon v. Ice, 555 U.S. 160,

170 (2009)). The doctrine of primary jurisdiction (or primary custody) has developed to address the issue of an individual who has violated the law of more than one sovereign. “‘Normally, the sovereign which first 3 arrests an individual acquires priority of jurisdiction for purposes of trial, sentencing and incarceration.’” United States v. Bates, 713 F.Supp. 3d

1153, 1155 (D.Utah 2024)(quoting United States v. Warren, 610 F.2d 680, 684-85 (9th Cir.1980)). The sovereign with priority of jurisdiction may exercise its discretion to relinquish that primary custody to another sovereign, but doing so is an executive, not a judicial, function. Bates, at

1155. The determination of custody and service of sentence between them is a matter of comity to be resolved by the executive branches of each sovereign. Id. (quoting Hernandez v. United States Att’y Gen., 689 F.2d 915, 917 (10th Cir.1982)).1

Resolving such inter-sovereign issues requires “a spirit of reciprocal comity and mutual assistance to promote due and orderly procedure” developed between sovereigns. Ponzi v. Fessenden, 258 U.S. 254, 259

(1922). Section 3623 is a codification of that comity from the federal perspective. “There is no express authority authorizing the transfer of a federal prisoner to a state court for such purposes.” Id. at 261-62. Now there is.

1Petitioner’s argument is that the federal government maintained primary jurisdiction so long as there was time to serve on the federal sentence. Thus, “[t]he Court should prevent Defendants from ending his federal sentence of life imprisonment and putting him to death.” (#2 at page 6 of 22 in CM/ECF pagination). 4 Petitioner nevertheless contends that the transfer was an ultra vires action that is subject to judicial review. He notes that the BOP guidance

statement provides that “[a]ny such transfer [under §3623] should occur within a reasonable period of time before the inmate’s release from a federal sentence, ordinarily within the last 90 days.” (#2-3 at 2). This guidance by its terms cannot apply to the case at bar. Petitioner was

serving a life sentence in the federal facility. There was no “last 90 days” to be measured. In any event, it is within the discretion of the BOP to elect not to follow its own guidance statement. Therefore, the

undersigned need not address Loper Bright Enters. v. Raimondo, 603 U.S. 369 (2024). “[W]hen it comes to deciding whether to relinquish ‘priority of jurisdiction’ over a defendant, the executive branch – not the judiciary – is the exclusive decisionmaker.” Bates, at 1155-56. (footnote

omitted). Petitioner asserts that under the statutory scheme, read as a whole, “[t]he whole idea of §3623 is for a federal inmate to complete his federal sentence in state custody, maintaining the primary jurisdiction until the

end of the sentence.” (#20 at 5). The undersigned disagrees. “Clearly, the federal government may waive jurisdiction.” United States v. Collier, 31 Fed.Appx. 161 (6th Cir.2002)(emphasis in original). In the next 5 sentence, the Collier court cited United States v. Warren, 610 F.2d 680, 684 (9th Cir.1980) for the proposition that sovereigns may elect under the

doctrine of comity to relinquish primary jurisdiction. In the undersigned’s view, a transfer pursuant to §3623 is such a temporary waiver or relinquishment. More to the point, (even assuming the BOP’s decision is subject to judicial review) it is within the federal sovereign’s discretion to

take such a view.

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Related

Ponzi v. Fessenden
258 U.S. 254 (Supreme Court, 1922)
Oregon v. Ice
555 U.S. 160 (Supreme Court, 2009)
Wilson v. State Of Oklahoma
335 F. App'x 783 (Tenth Circuit, 2009)
Setser v. United States
132 S. Ct. 1463 (Supreme Court, 2012)
Walter Leroy Moody, Jr. v. Warden Holman CF
887 F.3d 1281 (Eleventh Circuit, 2018)
United States v. Collier
31 F. App'x 161 (Sixth Circuit, 2002)
United States v. Warren
610 F.2d 680 (Ninth Circuit, 1980)

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Hanson v. Quick, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hanson-v-quick-oked-2025.