Facts of case
Benjamin Archuleta was charged with assaulting a federal official and found not guilty by reason of insanity (NGRI) in the United States District Court for the District of Utah on July 23, 1999. Based on a psychiatric evaluation and the testimony of others, the court ruled that Archuleta's release posed a substantial risk of harm to others and ordered him committed to the United States Medical Center for Federal Prisoners in Springfield, Missouri. Although later Archuleta was conditionally released, his release was revoked on July 8, 2002 and he was recommitted to FMC Springfield until the time he was determined to be eligible for a conditional release by the hospital; such release would be under court supervision. [4]
Archuleta filed a pro se petition (a petition to represent himself) for habeas corpus relief (seeking relief for unlawful detention) in the U.S. Court of Appeals for the Western District of Missouri in October, 2002, requesting an unconditional discharge and release from confinement in the prison hospital. He argued that the statute under which he was committed is unconstitutional because only a judicial unit, not an administrative one, can determine the length and conditions of his sentence and also whether his confinement after his successful NGRI defense could exceed the sentence he would have received if found guilty under the law. He further argued that his confinement in the prison facility far from the court was equal to "banishment and exile" and that "forced treatment" violated the Eighth Amendment. [2] [3] He also contested the finding that he had violated the terms of his conditional release, saying that he did not refuse the forced treatment "but for the exception of being late on taking his [anti-psychotic] medication... one day". [3] He also requested to withdraw his insanity defense. [2]
At the district court level, the counsel for both parties agreed to court’s interpretation of the pro se petition to focus on the issue of the involuntary administration of psychiatric medication. [5]
Decision
The appellate court ruled that although Archuleta's post-acquittal confinement was constitutional under statute 18 U.S.C. § 4243, [6] it decided to consider the unlawful detention question broadly as "substantial public interests are involved", as habeas corpus is a remedy available when no other is available. It ruled the lower court erred in overlooking the seriousness of the grievance, as the statute under which Archuleta was committed for involuntary treatment did not prevent him "from establishing by writ of habeas corpus the illegality of his detention". [5] Some issues, such as whether an insanity defense can be withdrawn upon appeal, have not been settled. [2]
The court vacated the dismissal order and remanded the case back to the district court, instructing that court to transfer the case to the U.S. District Court for the District of Utah, pursuant to 28 U.S.C. § 1406(a), [7] a statute which provides that the appellate court in which a case is wrongly filed may either dismiss it, or in the interest of justice, transfer the case to any district in which it could have been brought. [3]
The United States Court of Appeals for the Armed Forces is an Article I court that exercises worldwide appellate jurisdiction over members of the United States Armed Forces on active duty and other persons subject to the Uniform Code of Military Justice. The court is composed of five civilian judges appointed for 15-year terms by the president of the United States with the advice and consent of the United States Senate. The court reviews decisions from the intermediate appellate courts of the services: the Army Court of Criminal Appeals, the Navy-Marine Corps Court of Criminal Appeals, the Coast Guard Court of Criminal Appeals, and the Air Force Court of Criminal Appeals.
Rumsfeld v. Padilla, 542 U.S. 426 (2004), was a United States Supreme Court case, in which José Padilla, an American citizen, sought habeas corpus relief against Secretary of Defense Donald Rumsfeld, as a result of his detention by the military as an "unlawful combatant."
A writ of coram nobis is a legal order allowing a court to correct its original judgment upon discovery of a fundamental error that did not appear in the records of the original judgment's proceedings and that would have prevented the judgment from being pronounced.
Hamdan v. Rumsfeld, 548 U.S. 557 (2006), is a United States Supreme Court case in which the Court held that military commissions set up by the Bush administration to try detainees at Guantanamo Bay violated both the Uniform Code of Military Justice (UCMJ) and the Geneva Conventions ratified by the U.S.
Actual innocence is a special standard of review in legal cases to prove that a charged defendant did not commit the crimes that they were accused of, which is often applied by appellate courts to prevent a miscarriage of justice.
Day v. McDonough, 547 U.S. 198 (2006), is a US Supreme Court case involving the one-year statute of limitations for filing habeas corpus petitions that was established by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). In a 5–4 decision, the Court ruled that if the government unintentionally failed to object to the filing of a petition after the AEDPA limitations period has expired, it is not an abuse of discretion for a district court to dismiss sua sponte the petition on that basis.
Yasim Muhammed Basardah is a citizen of Yemen who was detained in the United States's Guantanamo Bay detention camps, in Cuba. His Guantanamo Internment Serial Number is 252. Basardah was an informant for the interrogators in Guantanamo where he was rewarded with his own cell, McDonald's apple pies, chewing tobacco, a truck magazine and other "comfort items".
The Military Commissions Act of 2006, also known as HR-6166, was an Act of Congress signed by President George W. Bush on October 17, 2006. The Act's stated purpose was "to authorize trial by military commission for violations of the law of war, and for other purposes".
In United States law, habeas corpus is a recourse challenging the reasons or conditions of a person's confinement under color of law. A petition for habeas corpus is filed with a court that has jurisdiction over the custodian, and if granted, a writ is issued directing the custodian to bring the confined person before the court for examination into those reasons or conditions. The Suspension Clause of the United States Constitution specifically included the English common law procedure in Article One, Section 9, clause 2, which demands that "The privilege of the writ of habeas corpus shall not be suspended, unless when in cases of rebellion or invasion the public safety may require it."
Ricardo Manuel Urbina was a United States district judge of the United States District Court for the District of Columbia. The first Latino judge on the United States District Court for the District of Columbia, he was noted for his rulings in cases regarding terrorism during the George W. Bush administration, as well as for his ruling in District of Columbia v. Heller, which was later reversed on appeal and by the United States Supreme Court.
Lefkowitz v. Newsome, 420 U.S. 283 (1975), is a U.S. Supreme Court case which held that when state law permits a defendant to plead guilty without giving up his right to judicial review of specified constitutional issues, such as the lawfulness of a search or the voluntariness of a confession, the defendant is not prevented from pursuing those constitutional claims in a federal habeas corpus proceeding.
Jimenez v. Quarterman, 555 U.S. 113 (2009), was a decision in which the Supreme Court of the United States held that under 28 U.S.C. § 2244(d)(1)(A), the conviction of a state defendant is not "final" if a state court grants an "out-of-time" appeal and the defendant has not yet filed a federal habeas petition.
Ahrens v. Clark, 335 U.S. 188 (1948), was a United States Supreme Court case that denied a federal district court jurisdiction to issue a writ of habeas corpus if the person detained is not within the territorial jurisdiction of the court when the petition is filed. The 6–3 ruling was handed down on June 21, 1948, with the majority opinion written by Justice William O. Douglas and the dissent written by Justice Wiley Blount Rutledge.
The Nonhuman Rights Project (NhRP) is an American nonprofit animal rights organization seeking to change the legal status of at least some nonhuman animals from that of property to that of persons, with a goal of securing rights to bodily liberty and bodily integrity. The organization works largely through state-by-state litigation in what it determines to be the most appropriate common law jurisdictions and bases its arguments on existing scientific evidence concerning self-awareness and autonomy in nonhuman animals. Its sustained strategic litigation campaign has been developed primarily by a team of attorneys, legal experts, and volunteer law students who have conducted extensive research into relevant legal precedents. The NhRP filed its first lawsuits in December 2013 on behalf of four chimpanzees held in captivity in New York State. In late 2014, NhRP President Steven Wise and Executive Director Natalie Prosin announced in the Global Journal of Animal Law that the Nonhuman Rights Project was expanding its work into other countries, beginning in Switzerland, Argentina, England, Spain, Portugal, and Australia.
In law, post conviction refers to the legal process which takes place after a trial results in conviction of the defendant. After conviction, a court will proceed with sentencing the guilty party. In the American criminal justice system, once a defendant has received a guilty verdict, they can then challenge a conviction or sentence. This takes place through different legal actions, known as filing an appeal or a federal habeas corpus proceeding. The goal of these proceedings is exoneration, or proving a convicted person innocent. If lacking representation, the defendant may consult or hire an attorney to exercise his or her legal rights.
McQuiggin v. Perkins, 569 U.S. 383 (2013), was a United States Supreme Court case in which the Court held that actual innocence, if proven, is sufficient to circumvent the one-year statute of limitations for petitioners to appeal their conviction enacted within the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
United States v. Morgan, 346 U.S. 502 (1954), is a landmark decision by the United States Supreme Court which provides the writ of coram nobis as the proper application to request federal post-conviction judicial review for those who have completed the conviction's incarceration in order to challenge the validity of a federal criminal conviction.
Kimmelman v. Morrison, 477 U.S. 365 (1986), was a decision of the U.S. Supreme Court that clarified the relationship of the right to effective assistance of counsel under the Sixth Amendment to other constitutional rights in criminal procedure. In this case, evidence against the defendant was probably seized illegally, violating the Fourth Amendment, but he lost the chance to argue that point due to his lawyer's ineffectiveness. The prosecution argued that the defendant's attempt to make a Sixth Amendment argument via a habeas corpus petition was really a way to sneak his procedurally defaulted Fourth Amendment claim in through the back door. The Court unanimously disagreed, and held that the Fourth Amendment issue and the Sixth Amendment issue represented different constitutional values, and had different requirements for prevailing in court, and therefore were to be treated separately by rules of procedure. Therefore, the habeas corpus petition could go forward. In its opinion, the Court also gave guidance on how to apply its decisions in Stone v. Powell and Strickland v. Washington.
Braden v. 30th Judicial Circuit Court of Kentucky, 410 U.S. 484 (1973), was a decision of the US Supreme Court regarding the statutory jurisdiction of federal district courts to grant writs of habeas corpus for guaranteeing the right of state prisoners to receive a speedy trial in another state under the Speedy Trial Clause of the Sixth Amendment to the US Constitution.
Brown v. Allen, 344 U.S. 443 (1953), is a landmark United States Supreme Court case about habeas corpus.
