explaining that “a federal court in the District of Columbia lacks jurisdiction to grant habeas relief from a Maryland conviction,” and any challenge to the U.S. Parole Commission’s reliance on the Maryland conviction “must proceed under the general 1 habeas statute . . . before a district judge who is capable of exercising personal jurisdiction over the warden of the prison where [the petitioner] is detained”
How later courts described this case
- explaining that “a federal court in the District of Columbia lacks jurisdiction to grant habeas relief from a Maryland conviction,” and any challenge to the U.S. Parole Commission’s reliance on the Maryland conviction “must proceed under the general 1 habeas statute . . . before a district judge who is capable of exercising personal jurisdiction over the warden of the prison where [the petitioner] is detained”
- stating that a petition challenging a Parole Commission’s supervised release revocation decision should be brought under § 2241 in the district of confinement
- finding that district courts may grant habeas writs only within their respective territorial jurisdictions
- “[T]his Court has no jurisdiction over [the habeas] petition, and will dismiss this case[.]”
Written by the judges who cited it.
The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
)
RONNIE L. HARRIS, )
)
Petitioner, )
)
v. ) Civil Action No. 15-1425 (KBJ)
)
UNITED STATES, )
)
Respondent. )
MEMORANDUM OPINION
Petitioner Ronnie L. Harris claims that he is “actually and factually innocent of
the retaliatory Maryland charges of which the United States Parole Commission based
its revocation of . . . parole,” and he seeks habeas relief under 28 U.S.C. § 2254. (Pet.
of Habeas Corpus Pursuant to Title 28 U.S.C. 2254(e)(2)(b), ECF No. 1.) For the
following reasons, this Court will DISMISS this case for want of jurisdiction.
First of all, although Harris’s petition appears to be based on a revocation of
parole that was executed by the state of Maryland, see Pet. at 4, 9, Harris is currently
incarcerated at the Federal Correctional Institution in Edgefield, South Carolina;
therefore, it is not entirely clear that Harris is actually “in custody pursuant to the
judgment of a State court[.]” 28 U.S.C. § 2254(a). Regardless, section 2254 of Title 28
of the United States Code authorizes federal courts “to entertain an application for a
writ of habeas corpus” that challenges a state court conviction under certain conditions.
See id § 2254(b)-(e). The district courts may grant “[w]rits of habeas corpus . . . within
their respective jurisdictions[,]” id. § 2241(a)(emphasis added), and that language has
been interpreted as “limit[ing] the power of a district court to hear and determine a
prisoner’s petition for habeas corpus to those situations where the prisoner both is
physically present in the court’s territorial jurisdiction and is detained or held in
custody within that jurisdiction.” U. S. ex rel. Rudick v. Laird, 412 F.2d 16, 20 (2d Cir.
1969).
Thus, a federal court in the District of Columbia lacks jurisdiction to grant
habeas relief from a Maryland conviction. Furthermore, to the extent that Harris is
challenging the U.S. Parole Commission’s reliance on the Maryland conviction to deny
or delay his release to parole, he must proceed under the general habeas statute, 28
U.S.C. § 2241, before a district court judge who is capable of exercising personal
jurisdiction over the warden of the prison where he is detained, which, in this case, is
the United States District Court for the District of South Carolina. See Stokes v. U.S.
Parole Comm’n, 374 F.3d 1235, 1239 (D.C. Cir. 2004) (“[A] district court may not
entertain a habeas petition involving present physical custody unless the respondent
custodian is within its territorial jurisdiction.”); Rooney v. Sec’y of Army, 405 F.3d
1029, 1032 (D.C. Cir. 2005) (habeas “jurisdiction is proper only in the district in which
the immediate . . . custodian is located”) (internal citations and quotation marks
omitted). Consequently, this Court has no jurisdiction over Harris’s petition, and will
dismiss this case without prejudice.
A separate order accompanies this Memorandum Opinion.
DATE: December 11, 2015 Ketanji Brown Jackson
KETANJI BROWN JACKSON
United States District Judge
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