Jiggetts v. State of Maryland
- Colleen McMahon
- 1:17-cv-06008
- U.S. District Court · Southern District of New York
- 2
In Jiggetts v. Maryland, Judge McMahon denied the motion to seal because transferring the case removed the court’s jurisdiction.
Alexander Jiggetts’s request to seal the transferred action was denied; any appeal from the order cannot proceed without the usual filing fees under the court’s certification.
What happened
Jiggetts v. State of Maryland began as a challenge to Alexander Jiggetts’s Maryland conviction. The court had transferred the case to the District of Maryland in 2017, and that court dismissed it because a civil damages lawsuit could not be used to challenge the validity of a criminal case.
Jiggetts later filed a motion in the Southern District of New York to seal the action. The court said that transferring the case had ended its jurisdiction over the case, and that Jiggetts had waited more than five years to seek relief. It therefore denied the motion to seal for lack of jurisdiction.
Judge Colleen McMahon also found that any appeal would not be taken in good faith and denied permission to proceed without paying the usual filing fees for an appeal. The court said Jiggetts would need to seek sealing in the District of Maryland and ask that court to transfer the case back if he wanted the Southern District of New York to consider the motion.
The detailed version
- Jiggetts v. State of Maryland · No. 1:17-cv-06008
- Colleen McMahon
- Mar. 9, 2023
Background
Alexander Jiggetts’s action challenged his Maryland conviction. In September 2017, the Southern District of New York transferred the action to the District of Maryland. The District of Maryland later dismissed the action because a civil lawsuit seeking damages could not be used to challenge the validity of a criminal case.
More than five years after the transfer, Jiggetts filed a motion in the Southern District of New York to seal the action.
Jurisdiction over the Motion
The court explained that transferring a case removes the transferring court’s authority to rule on the action. The transferring court retains authority to review the transfer only when the party seeking review acts to stop the transfer before the case papers reach the receiving court. Because Jiggetts waited more than five years to file the motion, the Southern District of New York concluded that it lacked jurisdiction to consider it.
The court stated that, if Jiggetts wanted the action sealed there, he would need to move in the District of Maryland and ask that court to transfer the action back to the Southern District of New York.
Ruling
Judge Colleen McMahon denied the motion to seal for lack of jurisdiction. The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied permission to proceed without paying the usual filing fees for purposes of an appeal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.