Jesse Cooley, Jr. v. JBS Mental Health, et al.

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

JESSE COOLEY, JR., Petitioner,

v. Case No. 2:25-cv-2107-CLM-JHE

JBS MENTAL HEALTH, et al., Respondents.

MEMORANDUM OPINION The magistrate judge has entered a report (doc. 18), recommending that the court dismiss Petitioner Jesse Cooley, Jr.’s 28 U.S.C. § 2254 petition for writ of habeas corpus without prejudice as unexhausted. Cooley objects to the report and recommendation. (Doc. 19). Cooley’s objections do not address the magistrate judge’s conclusion that his petition is unexhausted. Instead, to the extent that Cooley’s objections relate to the claims in his petition, Cooley’s objections concern the merits of his claims. For example, Cooley complains that the magistrate judge did not analyze the constitutional claims raised in his petition. (See id., pp. 4–5). But typically, “a federal court may not grant habeas corpus relief based upon claims that are unexhausted in state court.” Thompson v. Sec’y for Dep’t of Corr., 517 F.3d 1279, 1283 (11th Cir. 2008). Thus, because the magistrate judge correctly concluded that Cooley did not exhaust his claims in state court, the magistrate judge did not err by failing to address the merits of Cooley’s claims. Nor did the magistrate judge err in determining that the court couldn’t address many claims in Cooley’s petition, such as his claims related to inadequate meals and stolen property, because those claims aren’t cognizable in a habeas petition. See Pierre v. Rivkind, 825 F.2d 1501, 1504 (11th Cir. 1987) (“The writ of habeas corpus extends only to custody and detention; it cannot address collateral or ancillary forms of administrative relief.”). As a result, the court OVERRULES Cooley’s objections. In sum, having considered the entire record, including the report and recommendation, the court ADOPTS the magistrate judge’s report and ACCEPTS his recommendation. The court will enter a separate order that DISMISSES WITHOUT PREJUDICE Cooley’s habeas petition. DONE and ORDERED on September 4, 2026.

ae MAZE : UNITED STATES DISTRICT JUDGE