Williams v. Kimberly J. Maki
- Eric Tostrud
- 0:26-cv-00183
- U.S. District Court · District of Minnesota
- 4
Counsel of record per CourtListener. Firm names are approximate.
In Williams v. Maki, Judge Micko recommended denying Williams’s pretrial federal petition without prejudice and dismissing the case without prejudice.
Darryl Williams, whose federal challenge to his ongoing Minnesota state criminal prosecution was recommended for denial and dismissal without prejudice; the state prosecution was not ended by this report and recommendation.
What happened
In Darryl Williams v. Kimberly J. Maki, Williams asked the federal court to stop his ongoing Minnesota criminal prosecution, which involves charges of drug distribution, firearm or ammunition possession, obstructing legal process, and evading police.
The court said Williams could raise his claims in the state courts and found no extraordinary reason to interfere before trial. It therefore recommended denying his petition without prejudice, meaning he could potentially bring it again, and dismissing the case without prejudice.
Judge Douglas L. Micko also recommended denying Williams’s application to proceed without paying filing fees and issuing no certificate of appealability. The report is a recommendation, not a final order, and the parties may file objections.
The detailed version
- Williams v. Kimberly J. Maki · No. 0:26-cv-00183
- Eric Tostrud
- Jan. 20, 2026
Background
Darryl Williams is being prosecuted in Minnesota state court on charges of unlawful drug distribution, unlawful firearm or ammunition possession, obstructing legal process, and evading police. He filed a federal petition for a writ of habeas corpus under 28 U.S.C. § 2241, seeking to end the state criminal case. A habeas petition is a request for court relief from allegedly unlawful custody or prosecution.
The magistrate judge reviewed the petition under the preliminary-review rules that may be applied to habeas petitions. The opinion notes that Williams was not in custody under a state-court judgment, so his petition was not brought under 28 U.S.C. § 2254.
Reasoning
The court explained that, even though § 2241 does not expressly require exhaustion of state remedies, principles of respect for state courts and the federal system generally require state pretrial detainees to present their constitutional claims in state court before seeking federal habeas relief. Federal courts generally should not interfere with pending state judicial proceedings before trial and conviction unless extraordinary circumstances exist.
The court found no extraordinary circumstances here. It said Williams could raise his claim that the state courts lack jurisdiction in the state trial court and, if necessary, in the state appellate courts. It likewise concluded that his other claims should first be raised in state court. The possibility that the state courts might reject Williams’s arguments did not qualify as an extraordinary circumstance.
Recommendation and disposition
Judge Douglas L. Micko recommended that Williams’s habeas petition be denied without prejudice and that the case be dismissed without prejudice. The opinion states that, if Williams believes the prosecution violates state law, he may return to federal court if necessary after the criminal proceedings and any appeals conclude.
The court also recommended that Williams’s application to proceed without paying filing fees be denied. It further recommended that no certificate of appealability be issued. The report and recommendation is not a final order or judgment and is not directly appealable to the U.S. Court of Appeals for the Eighth Circuit. The notice states that a party may file specific written objections within 14 days after being served with the report.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.