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Keywords

tortplaintiffdefendantjurisdictionmotionhabeas corpuswill
defendantjurisdictionhabeas corpus

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Smothers v. United States, Not Reported in Fed. Supp., 2021 WL 765715

Facts

Plaintiff Rodney Smothers filed a motion asserting both habeas and tort claims against the Federal Bureau of Prisons, stemming from events during his confinement at the Yazoo Facility in Mississippi. He claimed constitutional and willful deprivation of his rights and alleged intentional and negligent torts by the Bureau of Prisons. The court found that it did not have personal jurisdiction over the warden of the Yazoo Facility, which led to the decision to transfer the case.

He is presently confined at the Yazoo Facility. (ECF No. 1-2 at PageID 19.) … the conduct from which the Non-Habeas Claims arise occurred at the Yazoo Facility (ECF No. 1 at PageID 1-17), which is in Yazoo City, Yazoo County, Mississippi – i.e., part of the Northern Division of the Southern District of Mississippi.

Issue

Whether the court has jurisdiction to hear Smothers's habeas corpus claims and non-habeas claims against the Federal Bureau of Prisons.

Whether the court has jurisdiction to hear Smothers's habeas corpus claims and non-habeas claims against the Federal Bureau of Prisons.

Rule

A petition for a writ of habeas corpus under 28 U.S.C. § 2241 must be filed in the district court that has jurisdiction over the petitioner's custodian, and a civil action must be brought in a judicial district where any defendant resides or where a substantial part of the events occurred.

A petition for a writ of habeas corpus under 28 U.S.C. § 2241 must be filed in the district court that has jurisdiction over the petitioner's custodian, and a civil action must be brought in a judicial district where any defendant resides or where a substantial part of the events occurred.

Analysis

The court analyzed the jurisdictional requirements for both the habeas and non-habeas claims. It concluded that it lacked personal jurisdiction over the warden of the Yazoo Facility, as he was not within the court's territorial jurisdiction. Additionally, the court found that the events giving rise to the non-habeas claims occurred at the Yazoo Facility, necessitating a transfer to the appropriate district.

The court analyzed the jurisdictional requirements for both the habeas and non-habeas claims. It concluded that it lacked personal jurisdiction over the warden of the Yazoo Facility, as he was not within the court's territorial jurisdiction.

Conclusion

The court transferred both the habeas and non-habeas claims to the Southern District of Mississippi due to lack of jurisdiction. The case was closed without entry of judgment.

Therefore, lacking jurisdiction, this Court TRANSFERS the Habeas Claims to the Southern District. Smothers should have brought his Non-Habeas Claims in the Southern District of Mississippi. Therefore, his Non-Habeas Claims are TRANSFERRED.

Who won?

The Federal Bureau of Prisons prevailed in the case as the court determined it lacked jurisdiction over the claims, leading to the transfer of the case to the appropriate district.

The Federal Bureau of Prisons prevailed in the case as the court determined it lacked jurisdiction over the claims, leading to the transfer of the case to the appropriate district.

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