Harris Sr. v. US Dept of Justice

CourtDistrict Court, District of Columbia
DecidedApril 17, 2023
DocketCivil Action No. 2023-0705
StatusPublished

This text of Harris Sr. v. US Dept of Justice (Harris Sr. v. US Dept of Justice) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harris Sr. v. US Dept of Justice, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

STEVEN JERMAINE HARRIS SR.,

Plaintiff,

v. Civil Action No. 1:23-cv-00705 (UNA)

U.S. DEPARTMENT OF JUSTICE, et al.,

Defendants.

MEMORANDUM OPINION

This matter is before the court on its initial review of plaintiff’s pro se pleading entitled

“judicial review according to Administrative Procedure Act,” ECF No. 2, which the court will

construe as a civil complaint. Upon review, and for the reasons explained below, the court will

dismiss the case without prejudice.

At the outset, the court notes that plaintiff’s application for leave to proceed in forma

pauperis, ECF No. 2, is not captioned for this court, in contravention of Federal Rule 10(a) and

D.C. Local Civil Rule 5.1(g), and will therefore be denied.

Plaintiff is an Oklahoma state prisoner who is a member of the Cherokee Nation. He sues

the United States Departments of Justice and Department of the Interior and alleges that an

Oklahoma state court was “without criminal jurisdiction” to prosecute, convict, and sentence him,

in violation of several federal laws and treaties. More specifically, because his alleged crimes

occurred on a reservation, he contends that they were subject only to federal prosecution. He seeks

to vacate his “illegal detention” by and through this court’s “review pursuant to the Administrative

Procedure Act (5 U.S.C. § 701 et seq) of [defendants’] failure to investigate and, if necessary, prosecute Oklahoma state officials for illegal detention of [plaintiff] and other[s] similarly situated

in state custody, and require said agencies to conduct and investigation as to whether Oklahoma

officials are violating federal law.” Plaintiff faces hurdles that he cannot overcome.

First, plaintiff should properly pursue these claims by filing a petition for writ of habeas

corpus. See 28 U.S.C. § 2254. Section 2254 authorizes federal courts to “entertain an application

for a writ of habeas corpus in behalf of a person in custody pursuant to the judgment of a State

court only on the ground that he is in custody in violation of the Constitution or laws or treaties of

the United States.” 28 U.S.C. § 2254. Before obtaining review, a plaintiff must first exhaust his

available state remedies. See 28 U.S.C. § 2254(b)(1). Such a petition may proceed only “in the

district court for the district wherein such person is in custody or in the district court for the district

[where] the State court was held which convicted and sentenced [petitioner][,] and each of such

district courts shall have concurrent jurisdiction to entertain the application.” 28 U.S.C. § 2241(d).

And if the petition is a second or successive one, the plaintiff first must “move in the appropriate

court of appeals for an order authorizing the district court to consider the application.” 28 U.S.C.

§ 2244(b)(3)(A). Consequently, plaintiff must pursue relief in the United States District Court for

the District of Oklahoma or in the United States Court of Appeals for the Tenth Circuit.

Second, because plaintiff may pursue relief by and through a petition for writ of habeas

corpus, there can be no of action under the APA to challenge the legality of his conviction or

detention “because that Act is limited to review of agency action ‘for which there is no other

adequate remedy.’” Vetcher v. Sessions, 316 F. Supp. 3d 70, 77–78 (D.D.C. 2018) (holding that

plaintiff may not bring claim under APA when habeas remedy was available) (quoting 5 U.S.C. §

704; citing Stern v. Fed. Bureau of Prisons, 601 F. Supp. 2d 303, 305 (D.D.C. 2009)).

Third, and similarly, the court notes that plaintiff passingly references the federal mandamus act, 28 U.S.C. § 1361, but mandamus is proper only if “(1) the plaintiff has a clear right

to relief; (2) the defendant has a clear duty to act; and (3) there is no other adequate remedy

available to plaintiff.” Council of and for the Blind of Delaware County Valley v. Regan, 709 F.2d

1521, 1533 (D.C. Cir. 1983) (en banc). As discussed, plaintiff has an available remedy in habeas.

See Muhammad v. Close, 540 U.S. 749, 750 (2004) (per curiam) (“Challenges to the validity of

any confinement or to particulars affecting its duration are the province of habeas corpus [.]”)

(citation omitted)); Morales v. Jones, 417 Fed. App’x 746, 749 (10th Cir. 2011) (“Absence of

jurisdiction in the convicting court is indeed a basis for federal habeas corpus relief cognizable

under the due process clause.”). And where “habeas is an available and potentially efficacious

remedy, it is clear beyond reasonable dispute that mandamus will not appropriately lie.”

Chatman–Bey v. Thornburgh, 864 F.2d 804, 806 (D.C. Cir. 1988).

Fourth, plaintiff cites, without explanation, to the All Writs Act, 28 U.S.C. § 1651, “but

there is no debate that the only court with authority to grant the writ is the court that issued the

underlying judgment or order that will be affected by granting the writ.” Aka v. Holder, No. 09

1526, 2009 WL 2496712, at *1 (D.D.C. Aug. 13, 2009) (citing United States v. Salgado, 692 F.

Supp. 1265, 1269 n.3 (E.D. Wash. 1988) (“The authorities are unanimous that only the court

rendering judgment has the power to issue an extraordinary writ. Thus, § 1651 does not create

jurisdiction, but merely allows a court to exercise continuing jurisdiction in aid of, or in

supervising, its own judgments.”); Telecommunications Research and Action Center v. Federal

Communications Commission, 750 F.2d 70, 77 (D.C. Cir. 1984) (“The All Writs Act is not an

independent grant of jurisdiction to a court; it merely permits a court to issue writs in aid of

jurisdiction acquired to grant some other form of relief.”)). Thus, plaintiff has no recourse in this

District to circuitously challenge his prosecution, conviction, or incarceration, under the All Writs Act.

Fifth, plaintiff recites 25 U.S.C. § 2802, which provides the Secretary of the Interior

responsibility in “providing, or for assisting in the provision of, law enforcement services in Indian

country[,]” see id. § 2802(a), including a specific list of those law enforcement and public safety

responsibilities, see id. § 280(b) et seq. While these responsibilities certainly exist, there is no

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Bordenkircher v. Hayes
434 U.S. 357 (Supreme Court, 1978)
Heckler v. Chaney
470 U.S. 821 (Supreme Court, 1985)
Muhammad v. Close
540 U.S. 749 (Supreme Court, 2004)
Sargeant, Donald B. v. Dixon, Harry
130 F.3d 1067 (D.C. Circuit, 1997)
Oxendine v. Williams
509 F.2d 1405 (Fourth Circuit, 1975)
Sattler v. Johnson
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Cox v. Secretary of Labor
739 F. Supp. 28 (District of Columbia, 1990)
Stern v. Federal Bureau of Prisons
601 F. Supp. 2d 303 (District of Columbia, 2009)
United States v. Salgado
692 F. Supp. 1265 (E.D. Washington, 1988)
United States Ex Rel. Rockefeller v. Westinghouse Electric Co.
274 F. Supp. 2d 10 (District of Columbia, 2003)
Vetcher v. Sessions
316 F. Supp. 3d 70 (D.C. Circuit, 2018)
Sibley v. Obama
866 F. Supp. 2d 17 (D.C. Circuit, 2012)

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