United States ex rel. Howard v. DeRobertis

595 F. Supp. 609, 1984 U.S. Dist. LEXIS 23232
CourtDistrict Court, N.D. Illinois
DecidedSeptember 27, 1984
DocketNo. 84 C 1153
StatusPublished

This text of 595 F. Supp. 609 (United States ex rel. Howard v. DeRobertis) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States ex rel. Howard v. DeRobertis, 595 F. Supp. 609, 1984 U.S. Dist. LEXIS 23232 (N.D. Ill. 1984).

Opinion

MEMORANDUM OPINION AND ORDER

ASPEN, District Judge:

Andrew Howard (“Howard”) filed a petition for habeas corpus pursuant to 28 U.S.C. § 2254, asserting that the Illinois Prisoner Review Board (“the Board”) denied him parole in violation of his rights under the Fifth and Fourteenth Amendments. Howard further claims that the Board failed to comply with a previous order of this Court dated October 17, 1983. Presently before the Court is respondent’s motion to dismiss Howard’s petition. For reasons set forth below, respondent’s motion to dismiss is granted.

Howard was convicted of gang related murder in December 1973 and is now serving a sentence of 150-200 years at Stateville Correctional Center.1 On February 2, 1983, pursuant to an application for rehearing, the Board denied Howard’s third application for parole. Thereafter, Howard filed a petition for writ of habeas corpus in this Court, asserting violations of his constitutional rights and requesting immediate release. In a prior action, this Court en[611]*611tered a summary judgment in favor of Howard and remanded the case to the Board for a rehearing consistent with our opinion.2 In response to that order, the Board held a rehearing on November 2, 1983, and issued an order and rationale denying Howard’s release on parole. The present petition for habeas corpus follows that denial.

Howard asserts several grounds for relief. First, he argues that the reasons given by the Board for denial of parole violated his constitutional rights. Second, Howard contends that the Board denied him due process in that it failed to comply with Ill.Rev.Stat. ch. 38, § 1003-5-1(b), which requires that an inmate be advised of factual information relied on whenever the Board makes a decision “which affects the length of the period of confinement or commitment.” Finally, Howard claims that the Board violated his due process rights by its failure to comply with this Court’s October 17, 1983 Opinion and Order.

I. Exhaustion

Howard did not petition the Illinois courts for a writ of mandamus. As a result, respondent moves to dismiss Howard’s petition on the ground that he has failed to exhaust his available state remedies as required by 28 U.S.C. § 2254(b) and (c). The federal habeas corpus statute requires that the district court dismiss a petition continuing any claims that have not been exhausted in the state courts. U.S. ex rel. Johnson v. McGinnis, 734 F.2d 1193 (7th Cir.1984), citing Rose v. Lundy, 455 U.S. 509, 102 S.Ct. 1198, 71 L.Ed.2d 379 (1982). The exhaustion requirement of section 2254, however, refers only to state remedies still available at the time the federal petition is filed. Engle v. Isaac, 456 U.S. 107, 125 n. 28, 102 S.Ct. 1558, 1570 n. 28, 71 L.Ed.2d 783 (1982). The exhaustion doctrine applies to a mandamus petition in state court where that proceeding could protect the rights asserted in the federal habeas corpus petition. Toney v. Franzen, 687 F.2d 1016, 1021 (7th Cir.1982) (citations omitted). Accordingly, we must determine whether a state mandamus remedy is available to Howard.

In United States ex rel. Johnson v. McGinnis, 734 F.2d 1193 (7th Cir.1984), the Court of Appeals for the Seventh Circuit held that before a state prisoner may obtain federal habeas corpus relief on the grounds that reasons given for his denial of parole violate the due process clause, he must first present that claim to the state courts by way of writ of mandamus. As the court observed,

Although Illinois mandamus is an unusual and extraordinary remedy, there do not appear to be any doctrinal or procedural bars that would prevent the Illinois courts from considering issues concerning the adequacy of reasons for a parole denial in a petition for a writ of mandamus. In fact, there is Illinois authority suggesting that mandamus is available in situations similar to the present case.

Id. at 1198.

The Johnson court examined Illinois law and concluded that a petition for writ of mandamus could be the proper procedure to compel the Board to provide a constitutionally adequate statement of reasons for a parole denial. Id. at 13. As a result, Howard should have petitioned the Illinois courts for a writ of mandamus. By not doing so, he has failed to exhaust all available state remedies.

II. The Ex Post Facto Clause Claim

While we have concluded that Howard has failed to exhaust available state remedies, examination of the merits of his peti[612]*612tion further supports our conclusion that it should be dismissed. Howard argues that the Board erroneously considered the nature and seriousness of his offense in denying his request for parole, thus violating his constitutional rights.3

In Heirens v. Mizell, 729 F.2d 449 (7th Cir.1984), an Illinois prisoner who had been denied parole release because of the seriousness of his offense sought federal habeas corpus relief. The court held that consideration of the nature and seriousness of the offense in making parole decisions was not a departure from prior practice of the Board, and thus did not result in an Ex Post Facto change in the law. Heirens v. Mizell, 729 F.2d at 463. Heirens thus reversed the earlier decision in Welsh v. Mizell, 668 F.2d 328 (7th Cir.), cert. denied, 459 U.S. 923, 103 S.Ct. 235, 74 L.Ed.2d 186 (1982). According to the Seventh Circuit, considerations of the seriousness of the offense committed by an inmate prior to 1973 no longer violates the Ex Post Facto clause of the U.S. Constitution.

In light of Heirens, Howard’s claim must fail. The Board properly considered the seriousness of his offense in denying his request for parole. Moreover, we agree with respondent that Howard was not denied parole solely on the basis of his crime. Rather, the Board’s decision noted Howard’s long arrest record and the court-imposed probation and supervision, both of which were drug related. Therefore, the denial of Howard’s parole request did not violate his constitutional rights.

III. Due Process Claims

Howard challenges the Board’s denial of parole with two procedural due process arguments. He first asserts that the decision was an arbitrary and capricious one as the Board’s denial points to no specific facts, circumstances or risks and thus is so vague as to violate due process.

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Bluebook (online)
595 F. Supp. 609, 1984 U.S. Dist. LEXIS 23232, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-ex-rel-howard-v-derobertis-ilnd-1984.