Adcock v. United States District Court for the District of Columbia
Civil Action No. 2017-0376
| D.D.C. | May 18, 2017Background
- Petitioner Roger Adcock is a federal inmate challenging his 2015 conviction for conspiracy to distribute narcotics.
- Adcock contends 18 U.S.C. § 3231 (1948) was unconstitutionally enacted (Quorum Clause challenge), so the Wyoming district court lacked jurisdiction.
- Adcock filed a § 2241 habeas petition in the U.S. District Court for the District of Columbia.
- At filing (and per BOP records), Adcock is confined at FCI Englewood in Colorado.
- The sentencing court was the U.S. District Court for the District of Wyoming; § 2255 authorizes collateral attacks in the sentencing court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the D.D.C. has jurisdiction to hear Adcock’s § 2241 petition | Adcock: D.C. court may hear because his conviction is invalid due to § 3231’s purported constitutional defect | Government: For custody-based habeas, only the district of confinement has jurisdiction; Adcock is confined in Colorado, not D.C. | Dismissed: D.D.C. lacks jurisdiction over this § 2241 petition (jurisdiction lies in district of confinement) |
| Proper vehicle for challenging sentencing-court jurisdiction | Adcock: Attacks constitutionality of § 3231 via § 2241 in D.C. | Government: Claims attacking conviction/sentencing court jurisdiction must proceed under 28 U.S.C. § 2255 in the sentencing court (D. Wyo.) | Adcock must raise his claim in a § 2255 motion in the sentencing court (D. Wyo.); D.C. court lacks authority to adjudicate it |
| Merits of the Quorum Clause challenge to § 3231 | Adcock: 1948 enactment of § 3231 violated Quorum Clause, rendering statute invalid | Government: Courts have repeatedly rejected the same Quorum Clause challenge as frivolous | Even assuming jurisdiction, the Quorum Clause claim is meritless and would be dismissed for failure to state a claim |
| Whether dismissal should be with leave to refile in proper court | Adcock: N/A (seeks relief here) | Government: Procedural requirement: use § 2255 in sentencing court | Court dismissed the § 2241 petition and indicated the District of Wyoming has jurisdiction over a § 2255 motion |
Key Cases Cited
- Rumsfeld v. Padilla, 542 U.S. 426 (2004) (habeas jurisdiction for present physical confinement lies only in the district of confinement)
- Taylor v. U.S. Bd. of Parole, 194 F.2d 882 (D.C. Cir. 1952) (challenge to sentence or court jurisdiction must be presented under § 2255 to the sentencing court)
- Wolford v. United States, [citation="362 F. App'x 231"] (3d Cir. 2010) (Quorum Clause challenges to the 1948 amendment enacting § 3231 are meritless)
- Cardenas-Celestino v. United States, 552 F. Supp. 2d 962 (W.D. Mo. 2008) (collecting and rejecting numerous frivolous Quorum Clause challenges)