HENDERSON
v.
GUALTIERI
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Henderson, a state prisoner, sought federal habeas corpus relief under 28 U.S.C. § 2241 challenging a state speedy trial violation. The district court dismissed the petition as premature for lack of exhaustion of state remedies and because § 2241 is limited to federal constitutional claims, not state procedural violations.
Henderson is not entitled to federal habeas corpus relief under § 2241 because (1) that statute is limited to violations of the U.S. Constitution, laws, or treaties—not state procedural rules—and (2) he failed to exhaust state court remedies before filing in federal court.
[1] Federal habeas corpus relief under 28 U.S.C. …
[2] Exhaustion of state court remedies is required before federal habeas corpus relief is available.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“because a court must afford a pro se party's paper a generous interpretation, Haines v. Kerner, 404 U.S. 519 (1972) (per curiam)”
Establishes the standard of review for pro se litigant filings; the court generously construes Henderson's motions despite procedural defects.
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Join FLexlaw to unlock all legal intelligenceHenderson was initially a pre-trial detainee in county jail when he filed his § 2241 habeas petition. By the time of this order, he had been convicted…
The full statement of facts, procedural history, and disposition for this case are member content.
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An earlier order (Doc. 2) dismisses as premature Henderson's application (Doc. 1) under 28 U.S.C. § 2241 for the writ of habeas corpus (1) because relief under Section 2241 is limited to the "violation of the Constitution or laws or treaties of the United States,” not the alleged violation of a state's speedy trial rule, and (2) because exhaustion of state court remedies is required before relief is available in federal court. A later order (Doc. 5) denies Henderson's paper captioned “Motion Confirming Exhaustion" (Doc. 4), which was construed as a motion under Rule 59(e), Federal Rules of Civil Procedure, to alter or amend a judgment.
Pending is Henderson's “Motion for a More Definite Statement Pursuant to Fed.R.Civ.P. 12(e),” in which Henderson objects to the reasons stated in the order (Doc. 2) that dismisses his action. Because a court must afford a pro se party's paper a generous interpretation, Haines v. Kerner, 404 U.S. 519 (1972) (per curiam), the motion is construed as moving for relief under Rule 60(b), Federal Rules of Civil Procedure, because Rule 12 applies to an opposing party's pleading and not to an order but Rule 60 affords a party the opportunity to obtain reconsideration of an order. Henderson is entitled to no relief under Rule 60. The earlier order that denies relief under Rule 59 explains that, because he is now in custody under a state court judgment and is no longer a pre-trial detainee, Henderson cannot obtain relief under Section 2241. The docket shows that that explanatory order (Doc. 5) was returned as undeliverable because Henderson was no longer in custody in the county jail. The pending motion shows that Henderson is now imprisoned in the Central Florida Reception Center for the Florida Department of Corrections.
Henderson's "Motion for a More Definite Statement Pursuant to Fed.R.Civ.P. 12(e) (Doc. 7), construed as a motion under Rule 60, Federal Rules of Civil Procedure, is DENIED. The clerk must forward to Henderson a copy of the earlier order (Doc. 5) that was returned as undeliverable.
ORDERED in Tampa, Florida, on July 11, 2024.
етипириции