Martin v. Warden, FCI Danbury
- Lewis Liman
- 1:24-cv-07231
- U.S. District Court · Southern District of New York
- 2
In Martin v. Warden, FCI Danbury, Judge Liman transferred Martin’s Section 2241 petition to Connecticut without reaching its merits.
Jovann L. Martin’s Section 2241 petition was transferred from the Southern District of New York to the District of Connecticut; the case was closed in the Southern District of New York.
What happened
Jovann L. Martin v. Warden, FCI Danbury concerns a petition Martin filed under 28 U.S.C. § 2241. The opinion says he filed it without a lawyer while incarcerated at FCI Danbury in Connecticut.
The court explained that a federal court generally handles a petition about a person’s physical confinement when the person is confined in that court’s district. Because FCI Danbury is in Connecticut, the court decided the case belonged in the District of Connecticut.
The court transferred the petition to the District of Connecticut and closed the case in the Southern District of New York. Judge Lewis J. Liman also denied Martin permission to proceed without paying filing fees if he appealed, certifying that an appeal would not be taken in good faith.
The detailed version
- Martin v. Warden, FCI Danbury · No. 1:24-cv-07231
- Lewis Liman
- Sept. 25, 2024
Background
Jovann L. Martin filed a petition under 28 U.S.C. § 2241 while incarcerated at FCI Danbury in Connecticut. He represented himself. The opinion does not describe the specific relief Martin sought or the underlying basis of his petition.
Reason for Transfer
The court explained that a court must have authority over the person responsible for a prisoner’s custody to decide a petition under Section 2241. For a petition concerning physical confinement, that authority generally exists in the federal district where the person is confined. FCI Danbury is located in the District of Connecticut.
Ruling
The court transferred the petition to the United States District Court for the District of Connecticut under 28 U.S.C. § 1406(a), stating that the transfer was in the interest of justice. The clerk was directed to transfer the action, and the order closed the case in the Southern District of New York. The court did not decide the merits of Martin’s petition.
The court also certified that any appeal would not be taken in good faith and denied Martin permission to appeal without paying filing fees. The opinion does not state any ruling by the District of Connecticut after the transfer.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.