Smith v. Warden of the Duluth Prison Camp
- Wilhelmina Wright
- 0:18-cv-02555
- U.S. District Court · District of Minnesota
- 2
In Smith v. Warden of the Duluth Prison Camp, Judge Wright denied Smith’s habeas petition and dismissed the action without prejudice for lack of subject-matter jurisdiction.
James C. Smith’s habeas action was denied and dismissed without prejudice; the Warden of the Duluth Prison Camp was the named defendant.
What happened
James C. Smith asked the federal court to grant his petition for a writ of habeas corpus. A magistrate judge recommended denying the petition, and no one filed objections to that recommendation.
Because there were no objections, the court reviewed the recommendation for clear error. The court found no clear error in the conclusion that it lacked authority to hear Smith’s claims.
Judge Wilhelmina M. Wright adopted the recommendation as modified, denied Smith’s petition, and dismissed the action without prejudice because the court lacked subject-matter jurisdiction.
The detailed version
- Smith v. Warden of the Duluth Prison Camp · No. 0:18-cv-02555
- Wilhelmina Wright
- July 24, 2019
Background
James C. Smith filed a petition for a writ of habeas corpus against the Warden of the Duluth Prison Camp. United States Magistrate Judge Leo I. Brisbois issued an April 23, 2019 Report and Recommendation recommending that the petition be denied. No objections were filed.
Court’s analysis
When no timely objections are filed, the district court reviews a magistrate judge’s report for clear error. The court found no clear error in the recommendation’s conclusion that the court lacked subject-matter jurisdiction over Smith’s claims. Subject-matter jurisdiction is the court’s legal authority to decide a case.
Because the court lacked subject-matter jurisdiction, it modified the recommendation to specify that the action would be dismissed without prejudice. The opinion does not explain the underlying claims or the specific reason the court lacked jurisdiction.
Disposition
Judge Wilhelmina M. Wright adopted the April 23, 2019 Report and Recommendation as modified, denied Smith’s habeas petition, and dismissed the action without prejudice. The court directed that judgment be entered accordingly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.