Antonio Doll v. Secretary, Florida Department of Corrections
15-13994
| 11th Cir. | Oct 27, 2017Background
- Antonio Doll, a Florida state prisoner, challenged that he is being held beyond the expiration of his sentence based on a 1994 nunc pro tunc order that he contends reduced his burglary sentence to 15 years.
- Sentencing transcript shows an oral designation as a habitual violent felony offender and an oral sentence of 30 years with a 15-year minimum on the burglary count; the original written sentencing order omitted the habitual-offender designation and the 15-year minimum.
- A 1994 nunc pro tunc order stated Doll "is sentenced as a violent habitual offender with fifteen (15) years of minimum mandatory imprisonment" for the burglary count.
- Doll pursued state relief (mandamus/habeas and multiple appeals) asserting the nunc pro tunc reduced his sentence; state courts concluded the nunc pro tunc merely corrected the written order to reflect the oral sentence and denied relief through 2014.
- Doll filed a § 1983 suit in federal court (seeking monetary damages) against FDOC officials for failing to effect his release; the district court dismissed on Rooker-Feldman and Younger grounds and alternatively granted summary judgment on the merits; the Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal jurisdiction—Rooker-Feldman application | Doll: federal court may review his § 1983 claim alleging unlawful continued detention | Defs: Rooker-Feldman bars federal review of state-court judgments | Rooker-Feldman did not bar the suit because state proceedings had not ended when Doll filed his federal complaint |
| Abstention—Younger doctrine | Doll: federal court should proceed; his claim seeks damages | Defs: federal court should abstain to avoid interfering with ongoing state proceedings | Younger potentially applied, but dismissal was improper; at most a stay was appropriate; any Younger error was harmless because state proceedings later ended and merits were addressed |
| Merits—Due process / § 1983 claim for continued detention | Doll: nunc pro tunc reduced sentence; defendants were deliberately indifferent by not releasing him | Defs: nunc pro tunc corrected the written order to reflect the original oral sentence; they reasonably relied on transcript and state law | Summary judgment for defendants: no reasonable juror could find deliberate indifference because defendants reasonably interpreted nunc pro tunc as clerical correction consistent with oral pronouncement |
| Proper remedy/procedure—untimely summary-judgment motion | Doll: defendants' summary-judgment motion was untimely and court should not have considered it | Defs: short delay and undisputed facts justify consideration | Court did not abuse discretion in considering the late motion due to judicial economy |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal courts cannot review state-court judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (same)
- Younger v. Harris, 401 U.S. 37 (abstention to avoid interference with state proceedings)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (limits of Rooker-Feldman)
- Lozman v. City of Riviera Beach, Fla., 713 F.3d 1066 (Rooker-Feldman timing analysis for when state proceedings have ended)
- Williams v. State, 957 So. 2d 600 (Fla. 2007) (oral pronouncement controls over written sentence)
- Cannon v. Macon Cty., 1 F.3d 1558 (continued detention after entitlement to release violates due process)
- Sprint Commc’ns, Inc. v. Jacobs, 134 S. Ct. 584 (federal courts’ obligation to exercise jurisdiction and limits on abstention)