Wyatt v. State of Texas
- Jeffrey White
- 4:22-cv-00437
- U.S. District Court · Northern District of California
- 2
In Wyatt v. State of Texas, Judge White dismissed the prisoner’s release claims because they must be brought through a habeas petition.
George Wyatt, who may pursue the requested release through a habeas petition rather than this Section 1983 action; the State of Texas and the other named defendants are no longer proceeding in this case.
What happened
George Wyatt, a Texas prisoner representing himself, filed a civil-rights complaint under a federal law known as Section 1983 against the State of Texas and others. He sought a pardon, clemency, an acquittal, and release from prison.
The court screened the complaint because prisoners suing government entities or officials must undergo an initial review. It explained that a petition for habeas relief—not a Section 1983 complaint—is the required way to seek immediate or faster release from state custody.
Judge Jeffrey S. White dismissed the case without prejudice to filing a habeas petition. The Clerk was directed to enter judgment and close the file.
The detailed version
- Wyatt v. State of Texas · No. 4:22-cv-00437
- Jeffrey White
- Feb. 24, 2022
Background
George Wyatt, identified as a Texas prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 against the State of Texas and other defendants. He sought a pardon, clemency, an acquittal, and release from prison. The court separately granted him permission to proceed without paying the filing fee.
Screening and legal issue
The court conducted the preliminary screening required for prisoner cases seeking relief from a government entity or government officer. Under 28 U.S.C. § 1915A, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a legally valid claim, or seek money from an immune defendant. The court also noted that pleadings filed without a lawyer must be read liberally.
The court focused on the requested release from state custody. It explained that release from state custody may be sought through a petition for a writ of habeas corpus under 28 U.S.C. § 2254. Habeas relief is the exclusive remedy for a prisoner seeking immediate or faster release from confinement. The opinion therefore did not decide whether Wyatt was entitled to a pardon, clemency, acquittal, or release on the merits.
Disposition
The court dismissed the case without prejudice to filing a petition for a writ of habeas corpus. It directed the Clerk to enter judgment and close the file. Judge Jeffrey S. White signed the order on February 24, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.