In Re: Burnside

CourtDistrict Court, M.D. Pennsylvania
DecidedJanuary 15, 2025
Docket1:24-cv-01960
StatusUnknown

This text of In Re: Burnside (In Re: Burnside) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Burnside, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA : Civil No. 1:24-CV-01960 : IN RE: : : BRIAN ARMOND BURNSIDE : : : : : Judge Jennifer P. Wilson MEMORANDUM On October 24, 2024, Brian Armond Burnside (“Defendant”) filed a notice of removal as to a criminal action filed against him in the York County Court of Common Pleas. (Doc. 1.)1 Defendant also filed multiple notices or affidavits of indigence and a certified prisoner trust fund account statement. (Docs. 2, 6, 12.) The court will construe Defendant’s affidavit of indigence as a motion to proceed in forma pauperis, grant the motion to proceed in forma pauperis, and remand the case back to the York County Court of Common Pleas because this court lacks jurisdiction. BACKGROUND AND PROCEDURAL HISTORY In the notice of removal, Defendant purports to remove criminal cases (Case Numbers CR-0004753, CR-0000115, MD-002031, and MD-000038) pending

1 The notice of removal was received and docketed by the court on November 5, 2024. against him in state court. (Doc. 1, p. 1.)2 With the notice of removal, Defendant also filed a notice by his spouse, Nicole Reneé Burnside (“Mrs. Burside”). (Doc.

9.) Attached to the notice of removal is an information sheet from the York County Clerk of Courts in the case Commonwealth v. Burnside, No. CP-67-CR- 0004753-2024. (Doc. 1-1.) According to this information sheet, there is a pending

criminal case against Defendant for twelve separate counts including fleeing or attempting to elude officer, firearms not to be carried without a license, possession of a prohibited firearm, recklessly endangering another person, marijuana in a small amount for personal use, use/possession of drug paraphernalia, disorderly

conduct, and receiving stolen property. (Doc. 1-1); Commonwealth v. Burnside, No. CP-67-CR-0004753-2024 (C.P. York Cnty.). Additionally, Defendant filed multiple notices that he also goes by the name

El Unus Per Some Bey direct ex relation to Brian Armond Burnside. (Docs. 5, 7, 8.) Defendant’s spouse also has pending criminal charges including with the same charges as Defendant. Commonwealth v. Burnside, No. CP-67-CR-0004749-2024 (C.P. York Cnty.).

Defendant filed a pro se notice of removal in his criminal action on October 25, 2024. Burnside, No. CP-67-CR-0004753-2024 (C.P. York Cnty.). There has been no such filing in Defendant spouse’s criminal action. Additionally,

2 For ease of reference, the court uses the page numbers from the CM/ECF header. Defendant’s spouse was not included on the notice of removal filed in the above captioned action. (Doc. 1.) Therefore, despite Mrs. Burnside’s affidavit stating

“[t]his Notice of Removal . . . is to go along with My Husband’s Notice of Removal 1:24-cv-1960 as Our STATE COURT cases are consolidated and we are in fact codefendants in the fraudulent unconstitutional matter,” Doc. 9, the court

views the above captioned matter as solely a notice of removal in Defendant’s state criminal action. The court received the certified prisoner trust fund account statement as required by 28 U.S.C. § 1915 on December 23, 2024. (Doc. 12.) The court will

now grant Defendant’s request to proceed in forma pauperis. However, Defendant’s removed criminal case will be remanded to the York County Court of Common Pleas because this court lacks subject matter jurisdiction.

DISCUSSION Federal courts are courts of limited jurisdiction, and are constrained to exercise only the authority conferred by Article III of the Constitution and affirmatively granted by federal statute. Moreover, federal law severely limits the

circumstances under which a litigant may remove a case from state court to federal court. See 28 U.S.C. §§ 1441–1455. Here, Defendant has not stated a valid basis for removal. When a defendant in a state criminal case files a notice of removal in a United States District Court, that court “shall examine the notice promptly.” 28 U.S.C. § 1455(b)(4). “If it clearly appears on the face of the notice and any exhibits annexed thereto that

removal should not be permitted, the court shall make an order for summary remand.” Id. In the context of criminal prosecutions, this court lacks subject matter

jurisdiction, except in certain narrow circumstances pursuant to 28 U.S.C. §§ 1442 (federal officers or agencies sued or prosecuted), 1442a (members of armed forces sued or prosecuted), or 1443 (civil rights cases). Defendant’s removal fails to qualify under any of these provisions, as discussed further below.

To qualify for removal pursuant to Section 1442, a removing party must establish that he is an officer of the United States or a person acting under an officer of the United States. 28 U.S.C. § 1442; see Pennsylvania v. Holloway, No.

24-2209, 2024 WL 5103009 (3d Cir. Dec. 13, 2024). Defendant references this statute by phrasing in his notice of removal: “I am Brian Armand Burnside misidentified as a defendant, Person or Actor being either a federal, state, or municipal agent or employee within the State of Pennsylvania . . . .” (Doc. 1, p. 1.)

Despite this obscure reference to Section 1442, Defendant makes no assertion that he is an officer of the United States or a person acting under an officer of the United States. Therefore, the court lacks jurisdiction under Section 1442. Removal under Section 1442a requires a removing party to show, among other things, that he is a member of the armed forces of the United States. 28

U.S.C. § 1442a; See Pennsylvania v. Smith, No. 24-1499, 2024 WL 3594362 (3d Cir. July 31, 2024). Defendant has not alleged that he is in the military. Thus, he has not alleged any facts supporting removal under Section 1442a.

Nor is this action removable under Section 1443. There are two ways an action is removable under Section 1443: (1) Against any person who is denied or cannot enforce in the courts of such State a right under any law providing for the equal civil rights of citizens of the United States, or of all persons within the jurisdiction thereof;

(2) For any act under color of authority derived from any law providing for equal rights, or for refusing to do any act on the ground that it would be inconsistent with such law.

28 U.S.C. § 1443. The Supreme Court specifically held that to establish jurisdiction under Section 1443(1), a defendant must satisfy the following two-pronged test: First, it must appear that the right allegedly denied the removal petitioner arises under a federal law ‘providing for specific civil rights stated in terms of racial equality.’ Georgia v. Rachel, supra, 384 U.S., at 792, 86 S.Ct. at 1790. Claims that prosecution and conviction will violate rights under constitutional or statutory provisions of general applicability or under statutes not protecting against racial discrimination, will not suffice. That a removal petitioner will be denied due process of law because the criminal law under which he is being prosecuted is allegedly vague or that the prosecution is assertedly a sham, corrupt, or without evidentiary basis does not, standing alone, satisfy the requirements of § 1443(1). City of Greenwood v. Peacock, supra, 384 U.S., at 825, 86 S.Ct., at 1811.

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Related

City of Greenwood v. Peacock
384 U.S. 808 (Supreme Court, 1966)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Johnson v. Mississippi
421 U.S. 213 (Supreme Court, 1975)
Pennsylvania v. Brown-Bey
637 F. App'x 686 (Third Circuit, 2016)

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