Renner v. Minnesota Department of Corrections
- Susan Nelson
- 0:19-cv-03007
- U.S. District Court · District of Minnesota
- 2
In Renner v. Minnesota Department of Corrections, Judge Nelson denied Jared Renner a certificate needed to appeal his habeas ruling.
Jared Renner was affected because the court denied the certificate required for him to appeal the earlier ruling on his federal custody petition. The Minnesota Department of Corrections was the respondent.
What happened
Jared Renner, representing himself, sought to appeal an earlier ruling on his petition challenging custody under federal law. The case returned to the District of Minnesota after the Court of Appeals sent it back in light of an earlier decision.
The court explained that a person generally needs a Certificate of Appealability to appeal an unfavorable ruling on a federal custody petition. The court denied the certificate because Renner had not shown that reasonable judges could disagree about the court’s evaluation of his constitutional claims. The opinion does not describe the underlying claims or the earlier ruling in detail.
Judge Susan Richard Nelson ruled that the Certificate of Appealability was denied. The order addressed only whether Renner could obtain the certificate; it did not decide the underlying constitutional claims in this order.
The detailed version
- Renner v. Minnesota Department of Corrections · No. 0:19-cv-03007
- Susan Nelson
- Oct. 20, 2020
Background
The order concerned Jared Renner’s petition under 28 U.S.C. § 2254, the federal procedure for challenging state custody. Renner was proceeding without a lawyer. The matter was before the District of Minnesota on remand from the United States Court of Appeals for the Eighth Circuit in light of Tiedeman v. Benson, 122 F.3d 518 (8th Cir. 1997).
Certificate of Appealability
The court explained that a petitioner under § 2254 generally may not appeal an unfavorable ruling on the petition unless the court grants a Certificate of Appealability. To obtain one, the petitioner must make a substantial showing that a constitutional right was denied. In practical terms, that requires showing that reasonable judges could debate whether the district court evaluated the constitutional claims correctly.
Ruling
The court found that Renner had not made the required showing. It therefore ordered that the Certificate of Appealability was denied. This order decided the request for permission to appeal, not the underlying constitutional claims; the opinion does not provide details about those claims or the earlier ruling on the petition.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.