McCann v. State of Mississippi

CourtDistrict Court, S.D. Mississippi
DecidedNovember 6, 2024
Docket2:23-cv-00151
StatusUnknown

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

Bluebook
McCann v. State of Mississippi, (S.D. Miss. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF MISSISSIPPI EASTERN DIVISION

FRANKIE L. MCCANN PETITIONER V. CIVIL ACTION NO. 2:23-CV-151-TBM-ASH STATE OF MISSISSIPPI RESPONDENT REPORT AND RECOMMENDATION

Pro se Petitioner Frankie L. McCann sued the State of Mississippi challenging his 2011 statutory rape guilty plea and sentence in the Circuit Court of Wayne County, Mississippi, and the resultant sex-offender-registration requirement. The Court construed McCann’s lawsuit as a habeas petition under 28 U.S.C. § 2254 and ordered Respondent to file an answer or other responsive pleading. Respondent moved to dismiss [17], and McCann responded with two motions for default judgment [18, 24] and a motion for relief [21]. As explained below, the undersigned recommends McCann’s motions be denied and this habeas petition dismissed for lack of jurisdiction. I. Facts and Procedural History On May 16, 2011, McCann pleaded guilty to a charge of statutory rape in Wayne County. On June 30, 2011, the Wayne County Circuit Court sentenced McCann to twenty years in the custody of the Mississippi Department of Corrections, with fifteen years suspended, to be followed by a five-year term of supervised probation. On August 22, 2015, MDOC discharged McCann from its custody at the expiration of his sentence. McCann’s supervised probation was revoked once in 2016, and on August 12, 2020, McCann completed his term of supervised probation. More than three years later, on October 12, 2023, McCann filed this § 2254 petition. His Amended Petition [12] includes four grounds: Ground One: McCann was coerced into falsely incriminating himself. Am. Pet. [12] at 5. Ground Two: McCann was denied due process. Id. at 7. Ground Three: McCann was deprived of individual dignity and equal protection of the law. Id. at 8. Ground Four: The State discriminated against McCann. Id. at 10. As relief, McCann asks that the Court (1) order the “dismissal of [the] statutory rape [conviction] from [his] record,” (2) “relieve[ him] of [his] duty to register” as a sex offender, and (3) award him “$70,000 for the wrongful conviction.” Id. at 15. On April 23, 2024, the Court entered an order severing the request for damages into a separate action under 42 U.S.C. § 1983. Order [30]. Respondent filed a motion to dismiss [17], to which McCann responded [25], and Respondent filed a timely reply [28]. McCann filed three motions of his own [18, 21, 24] as well as some additional documents. The undersigned has considered all of McCann’s filings. II. Analysis A. McCann’s Motions On February 28, 2024, United States Magistrate Judge F. Keith Ball entered an Order

[14] directing Respondent to “file an answer or other responsive pleading in this cause within 20 days of the service . . . of a copy of this order.” The Order also required Respondent to “file with [its] answer or other responsive pleading full and complete transcripts of all proceedings in the state court . . . arising from Petitioner’s statutory rape conviction.” Order [14]. Respondent was served on March 4, 2024, making its answer or responsive pleading due on or before March 24, 2024. Acknowledgment of Service [16].1 Respondent moved to dismiss on March 22, 2024. Believing Respondent failed to comply with the Court’s order, McCann filed three motions essentially seeking a default judgment in his favor on his claims. Mot. [18] at 2 (asking the Court to rule in his favor “d[ue] to lack of response from Respondent within time[]frame

giv[en] by” Court); Mot. [21] at 1, 2 (“asking the court “to order relief requested” because Respondent “fail[ed] to answer or respond to charges or claims”); Mot. [24] at 1 (seeking “default judgment because Respondent failed to answer or deny allegation[s] in petition[]”). He also complains that Respondent “failed to produce transcript[s] ordered by [the] court.” Mot. [24] at 1. Starting with the transcripts, in its motion to dismiss, Respondent represented that “[t]he Wayne County Circuit Court Clerk’s Office advised . . . that it has no transcripts concerning McCann’s 2011 statutory rape plea and sentence.” Mot. [17] at 1 n.1; see also Resp. [32] at 2.2 Respondent cannot produce what does not exist. Its failure to produce transcripts does not entitle

McCann to any relief. As for whether Respondent defaulted, its motion to dismiss was timely filed. Rule 4 of the Rules Governing Section 2254 Cases provides that if the Court does not summarily dismiss a petition, “the judge must order the respondent to file an answer, motion, or other response within a fixed time.” The advisory committee notes to the 2004 amendments state “that the response to

1 The Acknowledgment of Service appears to show service on March 14, but it was filed on March 7. See Acknowledgment of Service [16]. 2 Respondent indicated that “[i]f th[e] Court determines that transcripts are necessary for proper disposition of th[e] case, [it] will request the transcripts from the court reporter and, if available, file them with th[e] Court upon request.” Mot. [17] at 1 n.1. Given the Court’s recommendation on the merits, transcripts of the state-court proceedings are not necessary. a habeas petition may be a motion.” And Rule 12 of the Rules Governing Section 2254 Cases states that the Federal Rules of Civil Procedure, “to the extent that they are not inconsistent with any statutory provisions or these rules, may be applied to a proceeding under these rules.” Respondent filed its motion under Federal Rule of Civil Procedure 12(b), which provides that a motion to dismiss “must be made before pleading if a responsive pleading is allowed.” McCann

has not shown that Federal Rule of Civil Procedure 12(b) is inconsistent with the Rules Governing Section 2254 cases. Respondent timely moved to dismiss, discharging its pleading obligations.3 The undersigned therefore recommends McCann’s motions [18, 21, 24] be denied. B. Respondent’s Motion to Dismiss “A state prisoner is entitled to relief under 28 U.S.C. § 2254 only if he is held ‘in custody in violation of the Constitution or laws or treaties of the United States.’” Engle v. Isaac, 456 U.S. 107, 119 (1982) (quoting 28 U.S.C. § 2254(a)). The Supreme Court “ha[s] interpreted the statutory language as requiring that the habeas petitioner be ‘in custody’ under the conviction or sentence under attack at the time his petition is filed.” Maleng v. Cook, 490 U.S. 488, 490–91

(1989). A habeas petitioner does not “remain[] ‘in custody’ under a conviction after the sentence imposed for it has fully expired.” Id. at 492. That is so even if some “collateral consequences” of a fully expired conviction remain. Id. A judge of the Fifth Circuit ruling on a motion for a certificate of appealability recently observed that the Fifth Circuit “has twice held that a petitioner’s ‘obligation to register as a sex offender does not render him “in custody” for purposes of a § 2254 challenge.’” Lempar v.

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Bluebook (online)
McCann v. State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccann-v-state-of-mississippi-mssd-2024.