Harris v. United States

Background

Donte Harris, who was incarcerated at FCI Schuylkill in Minersville, Pennsylvania, filed a petition under 28 U.S.C. § 2241 challenging his detention. He filed the petition without a lawyer. The opinion states that Harris originally submitted the matter as a letter in his criminal case, and that Judge Lewis J. Liman directed the Clerk of Court to open a new civil action under Section 2241.

Court’s analysis

For a petition under Section 2241 challenging physical confinement, the court generally must have jurisdiction—legal authority over—the petitioner’s custodian. The opinion explains that this jurisdiction generally lies in the federal district where the petitioner is confined. Because FCI Schuylkill is in the Middle District of Pennsylvania, the Southern District of New York determined that the case should be transferred there in the interest of justice under 28 U.S.C. § 1406(a). The court did not decide whether Harris’s detention was lawful.

Disposition

Judge Laura Taylor Swain ordered the Clerk of Court to transfer the action to the United States District Court for the Middle District of Pennsylvania. The order closed the case in the Southern District of New York. It left the decision on whether Harris could proceed without paying fees to the receiving court. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.

Classification rationale

This is a procedural order because the court transferred the petition based on the proper court’s authority over the custodian and did not reach the merits of Harris’s detention challenge.