Mitchell v. Lucus

CourtDistrict Court, E.D. Wisconsin
DecidedJune 29, 2021
Docket2:20-cv-01707
StatusUnknown

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

Bluebook
Mitchell v. Lucus, (E.D. Wis. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

ANTOWINE MITCHELL,

Petitioner, Case No. 20-cv-1707-pp v.

EARL LUCUS,

Respondent.

ORDER DENYING HABEAS PETITION (DKT. NO. 1), DECLINING TO ISSUE CERTIFICATE OF APPEALABILITY AND DISMISSING CASE WITHOUT PREJUDICE

On November 12, 2020, the petitioner, representing himself, filed a petition for writ of habeas corpus under 28 U.S.C. §2241. Dkt. No. 1. His petition challenges his pretrial detention in Milwaukee County Case No. 2018CF3584, arguing (1) that the Milwaukee County Circuit Court violated his right to a speedy trial, (2) that the court improperly denied his motion for bond after it granted a mistrial, and (3) the state court had yet to rule on the petitioner’s “Motion to Bar Retrial Double Jeopardy.” Id. at 10-11. For relief, the petitioner asks this federal court “to reconsider dismissal from first trial” and to be released from custody. Id. at 12. On January 4, 2021, the petitioner filed a motion to proceed without prepaying the $5.00 filing fee. Dkt. No. 5. Two weeks later, the court received the fee. This order dismisses the §2241 petition, denies as moot the motion to proceed without prepaying the filing fee and dismisses the case without prejudice. I. Rule 4 Screening A. Standard Under Rule 1(b) of the Rules Governing Section 2254 Cases and Civil Local Rule 9(a)(2) of the Local Rules for the Eastern District of Wisconsin, the

court applies the Rules Governing Section 2254 Cases to petitions for a writ of habeas corpus under 28 U.S.C. §2241. Rule 4 of the Rules Governing §2254 proceedings provides: If it plainly appears from the face of the petition and any attached exhibits that the petitioner is not entitled to relief in the district court, the judge must dismiss the petition and direct the clerk to notify the petitioner. If the petition is not dismissed, the judge must order the respondent to file an answer, motion or other response within a fixed time, or to take other action the judge may order.

A court allows a habeas petition to proceed unless it is clear that the petitioner is not entitled to relief in the district court. At the screening stage, the court expresses no view as to the merits of any of the petitioner’s claims. Instead, the court considers whether the petitioner has stated cognizable grounds for federal habeas relief and whether the petitioner has exhausted his state court remedies. “The appropriate vehicle for a state pre-trial detainee to challenge his detention is § 2241.” Jackson v. Clements, 796 F.3d 841, 843 (7th Cir. 2015). While §2241 allows a pretrial detainee to petition for habeas relief, the Younger abstention doctrine limits the ability of a federal court to interfere with pending state criminal prosecutions absent special circumstances. See, e.g., Olsson v. O’Malley, 352 F. App’x. 92, 94 (7th Cir. 2009) (citing Younger v. Harris, 401 U.S. 37, 43-45 (1971)). Exceptional circumstances exist where irreparable damage would occur, such as when the plaintiff claims the criminal case resulted from prosecutorial harassment or that the prosecution was brought in bad faith. Younger, 401 U.S. at 49. Generally, relief is available only after the

petitioner has exhausted state-court remedies. Olsson v. Curran, 328 F. App’x. 334, 335 (7th Cir. 2009). Exceptional circumstances do not exist when the threatened injury “is solely ‘that incidental to every criminal proceeding brought lawfully and in good faith.’” Younger, 401 U.S. at 49 (citing Douglas v. City of Jeannette, 319 U.S. 157, 164 (1943)). B. Analysis In the section of the form petition asking the petitioner to describe the type of decision or action that he is challenging, the petitioner wrote:

Speedy trial demand violation. No bond on 90th day. 92nd day trial started, 93rd day mistrial was granted dismissal denied. Discovery violation and changed statement violation. Bond was denied[.]

Dkt. No. 1 at 2. In the section asking him to identify the case or docket number of the case in which he is detained, the defendant wrote, “Milwaukee County Courthouse Branch 28,” and identified the case number as “18CF3584.” Id. at 4. The court checked the publicly available state-court docket, which shows that the State filed a criminal complaint against the petitioner on July 31, 2018. State v. Mitchell, Milwaukee County Case No. 18CF3584 (available at https://wcca.wicourts.gov). The docket shows that the charges in that case went to trial before a jury on March 8, 2021, and that on March 10, 2021, the jury found the petitioner guilty of two counts of armed robbery, one count of operating a vehicle without the owner’s consent and two counts of false imprisonment. Id. It reflects that on May 21, 2021, the circuit court sentenced the petitioner to twenty-two years and nine months of initial confinement

followed by fifteen years of extended supervision. Id. On Jun 2, 2021, the clerk of the Milwaukee County Circuit Court issued the judgment of conviction. Id.1 “Because a pre-trial detainee is not yet ‘in custody pursuant to the judgment of a State court,’ relief under 28 U.S.C. § 2254 is not available.” Jackson, 796 F.3d. at 843 (citing Jacobs v. McCaughtry, 251 F.3d 596, 597-98 (7th Cir. 2001)). If the petitioner is convicted in state court while the federal habeas petition is pending, however, “the claims concerning his pre-trial confinement become moot.” Id. (citing Yohey v. Collins, 985 F.2d 222, 228-29

(5th Cir. 1993)). A jury has found the petitioner guilty, and the Milwaukee County Circuit Court has sentenced him. Under Jackson, the petitioner’s claims about his pretrial proceedings became moot once the state court entered the judgment of conviction; his continued detention now is the result of that

1 Regarding the petitioner’s allegations that the state court declared a mistrial, the public docket shows that the court selected a jury on July 24, 2019 and that trial began on that date, with the court instructing the jurors, the lawyers giving opening statements and five witnesses testifying. But on July 25, 2019, the court declared a mistrial “[b]ased on the statements put forth,” denied a motion to dismiss and motion to adjust bond, and scheduled a final pretrial conference for August 28, 2019 and a trial for October 7, 2019. State v. Mitchell, Milwaukee County Case No. 18CF3584 (available at https://wcca.wicourts.gov). In late 2019 and early 2020, the case was adjourned because the defendant expressed an intention to file motions, including a motion regarding double jeopardy. Then the COVID-19 pandemic hit in March 2020. The court ruled on the pending motions in August 2020 and January 2021. The jury trial referenced above followed. Id. state court judgment. That means that if he wants to challenge his confinement, he must do so under 28 U.S.C. §2254, not §2241. See Walker v. O’Brien, 216 F.3d 626, 633 (7th Cir. 2000) (a petitioner must proceed under 28 U.S.C.

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Fenner v. Boykin
271 U.S. 240 (Supreme Court, 1926)
Douglas v. City of Jeannette
319 U.S. 157 (Supreme Court, 1943)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Nelson v. Adams USA, Inc.
529 U.S. 460 (Supreme Court, 2000)
Chris Jacobs, Applicant v. Gary R. McCaughtry
251 F.3d 596 (Seventh Circuit, 2001)
Gray v. Hardy
598 F.3d 324 (Seventh Circuit, 2010)
Blanck v. Waukesha County
48 F. Supp. 2d 859 (E.D. Wisconsin, 1999)
Floyd Richardson v. Michael Lemke
745 F.3d 258 (Seventh Circuit, 2014)
Andre Jackson v. Marc Clements
796 F.3d 841 (Seventh Circuit, 2015)

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Bluebook (online)
Mitchell v. Lucus, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-lucus-wied-2021.