Pennington v. Darrow

CourtDistrict Court, C.D. Illinois
DecidedApril 11, 2023
Docket1:23-cv-01006
StatusUnknown

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

Bluebook
Pennington v. Darrow, (C.D. Ill. 2023).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION

ROBERT L. PENNINGTON, JR., ) ) Plaintiff, ) ) v. ) 23-1006 ) SARA L. DARROW, et al. ) ) Defendants. )

MERIT REVIEW ORDER Plaintiff, proceeding pro se and presently detained at the Knox County Jail in Galesburg, Illinois, was granted leave to proceed in forma pauperis. The case is now before the Court for a merit review. As an initial matter, Plaintiff filed a motion seeking leave to file an amended complaint. (Doc. 6). Plaintiff’s motion is granted. Fed. R. Civ. P. 15(a)(1). The Court will consider only the allegations in Plaintiff’s amended complaint without reference to his original complaint. The Court must “screen” Plaintiff’s amended complaint, and through such process to identify and dismiss any legally insufficient claim, or the entire action if warranted. 28 U.S.C. § 1915A. A claim is legally insufficient if it “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id. The Court accepts the factual allegations as true, liberally construing them in Plaintiff's favor. Turley v. Rednour, 729 F.3d 645, 649 (7th Cir. 2013). Conclusory statements and labels are insufficient—the facts alleged must “state a claim for relief that is plausible on its face.” Alexander v. U.S., 721 F.3d 418, 422 (7th Cir. 2013) (citation omitted). ALLEGATIONS Plaintiff alleges constitutional violations arising from his federal criminal proceedings. Defendant Darrow is the Chief U.S. District Judge for the Central District of Illinois before whom Plaintiff’s federal criminal charges are pending. Defendants Zopf, Jaeger, McCall, and

Fultz are attorneys who represented or are currently representing Plaintiff in those proceedings. Plaintiff alleges that his federal criminal proceedings from 2020 through fall 2022 were conducted in Davenport, Iowa, a location that is not within the Central District of Illinois where the criminal charges were filed.1 He alleges that he did not consent to proceedings at this location, and, therefore, Defendant Darrow lacked jurisdiction and legal authority to preside over his case. The docket in Plaintiff’s criminal case indicates that he is awaiting sentencing following a guilty plea entered on September 22, 2022. United States v. Pennington, No. 18-20021, Minute Entry dated Sept. 22, 2022 (C.D. Ill.). Plaintiff submitted on that date a signed consent to conduct all proceedings in Davenport, Iowa. Id., ECF No. 216. Plaintiff alleges that Defendants Zopf, Jaeger, McCall, and Fultz did not advise him of

his right to object to the location of these proceedings, nor did they object on his behalf. Plaintiff alleges that Defendant Darrow appointed these and other unnamed defendants to represent him in his criminal case “knowing that these individuals would not challenge her jurisdiction authority.” (Doc. 6 at 8). Plaintiff seeks injunctive relief, including an order vacating all orders that were “heard without territory” and permitting re-litigation of same, monetary damages, and criminal indictments. (Doc. 6 at 14).

1 On September 26, 2018, Judge Shadid, the Chief U.S. District Judge for the Central District of Illinois at the time, issued General Order No. 18-05. The order authorized the Rock Island Division of the Central District of Illinois to conduct special sessions pursuant to the Federal Judiciary Emergency Special Sessions Act of 2005, 28 U.S.C. § 141, at the United States Courthouse for the Southern District of Iowa located in Davenport, Iowa, effective immediately. DISCUSSION Plaintiff asserts a claim under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), based on an alleged violation of his Sixth Amendment right to a trial in the State and district where his alleged crimes occurred. U.S. Const., Amend. VI (“In all

criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed….”). Bivens created an implied private cause of action for money damages against federal officers who violate an individual’s Fourth Amendment rights. Bivens, 403 U.S. at 397. The holding “recognized for the first time an implied private action for damages against federal officers alleged to have violated a citizen’s constitutional rights.” Corr. Srvcs. Corp. v. Malesko, 534 U.S. 61, 66 (2001), but the Supreme Court has cautioned against extending this remedy to new contexts. Ziglar v. Abbasi, 137 S. Ct. 1843, 1857 (2017). Since Bivens, the Supreme Court has found an implied cause of action to exist under Bivens only twice—to medical claims arising under the Eighth Amendment and to Fifth Amendment due process claims based on gender

discrimination. Id. at 1854-55. The Supreme Court has not recognized a Bivens remedy for claims arising under the Sixth Amendment. Sebolt v. Samuels, 749 F. App’x 458, 459 (7th Cir. 2018). The Supreme Court has made clear “that a Bivens remedy will not be available if there are special factors counselling hesitation in the absence of affirmative action by Congress.” Ziglar, 137 S. Ct. at 1857-58 (internal quotations omitted). Thus: if there are sound reasons to think Congress might doubt the efficacy or necessity of a damages remedy as part of the system for enforcing the law and correcting a wrong, the courts must refrain from creating the remedy in order to respect the role of Congress in determining the nature and extent of federal-court jurisdiction under Article III. Id. at 1858. “When a party seeks to assert an implied cause of action under the Constitution itself…separation-of-powers principles are or should be central to the analysis. The question is ‘who should decide’ whether to provide for a damages remedy, Congress or the courts?” Id. (citing Bush v. Lucas, 462 U.S. 367, 390 (1983)).

Article III vests with Congress the power to create the district courts. U.S. Const., Art. III, § 1 (“The judicial Power of the United States, shall be vested in one supreme Court, and in such inferior Courts as the Congress may from time to time ordain and establish.”) (emphasis added). Congress defines the geographical location of the federal judicial districts and the parameters under which the district courts operate. 28 U.S.C. §§ 81-143. The Federal Judiciary Emergency Special Sessions Act of 2005, 28 U.S.C. § 141, authorizes a district court to conduct court proceedings outside of its own district if certain criteria are met, and, if met, permits the district court to conduct “any business which may be transacted at a regular session,” except that a criminal trial may not be conducted out of state without the defendant’s consent. 28 U.S.C. § 141(b)(1)-(2).

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Related

Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Bush v. Lucas
462 U.S. 367 (Supreme Court, 1983)
Correctional Services Corp. v. Malesko
534 U.S. 61 (Supreme Court, 2001)
Ralph Dupoint v. United States
388 F.2d 39 (Fifth Circuit, 1968)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Ziglar v. Abbasi
582 U.S. 120 (Supreme Court, 2017)
William Watts v. Mark Kidman
42 F.4th 755 (Seventh Circuit, 2022)

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Pennington v. Darrow, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pennington-v-darrow-ilcd-2023.