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Keywords

jurisdictionstatutehabeas corpusrespondent

Related Cases

Rumsfeld v. Padilla

Facts

Respondent Jose Padilla is a United States citizen detained by the Department of Defense pursuant to the President's determination that he is an 'enemy combatant' who conspired with al Qaeda to carry out terrorist attacks in the United States. On May 8, 2002, Padilla flew from Pakistan to Chicago's O'Hare International Airport, where he was apprehended by federal agents executing a material witness warrant. He was then held in federal custody until the President ordered his detention in military custody on June 9, 2002. Padilla's counsel filed a habeas corpus petition in the Southern District of New York, naming the Secretary of Defense and the facility commander as respondents.

On May 8, 2002, Padilla flew from Pakistan to Chicago's O'Hare International Airport, where he was apprehended by federal agents executing a material witness warrant. He was then held in federal custody until the President ordered his detention in military custody on June 9, 2002.

Issue

Did Padilla properly file his habeas petition in the Southern District of New York?

Rule

The federal habeas statute provides that the proper respondent to a habeas petition is 'the person who has custody over [the petitioner].'

The federal habeas statute straightforwardly provides that the proper respondent to a habeas petition is 'the person who has custody over [the petitioner].'

Analysis

The Court applied the immediate custodian rule, which states that the proper respondent in a habeas corpus petition is the warden of the facility where the prisoner is being held. In this case, the Court determined that Commander Marr, the commander of the military facility where Padilla was detained, was the only proper custodian for the habeas petition, not Secretary Rumsfeld. The Court found that the traditional habeas corpus jurisdiction rules were not altered by the unique circumstances of Padilla's case.

The Court applied the immediate custodian rule, which states that the proper respondent in a habeas corpus petition is the warden of the facility where the prisoner is being held.

Conclusion

The judgment upholding jurisdiction over the detainee's petition was reversed, and the case was remanded for entry of an order of dismissal without prejudice.

Who won?

The petitioners, Secretary of Defense Donald H. Rumsfeld and Commander Marr, prevailed because the Supreme Court held that the proper respondent to the habeas petition was the immediate custodian, Commander Marr, and not the Secretary.

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