Bryant v. Carnajia, 3:21-cv-00426

Petitioner Ronnie Leon Bryant is incarcerated in Virginia and challenged a conviction and unserved sentence imposed by the D.C. Superior Court.
Bryant filed a petition labeled as brought under 28 U.S.C. § 2255 in the Eastern District of Virginia seeking relief from the D.C. conviction/sentence.
The record shows Bryant has repeatedly attempted to challenge his D.C. conviction in various courts.
The Eastern District concluded that collateral challenges to D.C. Superior Court convictions must be pursued in the D.C. Superior Court under D.C. law.
The court denied and dismissed Bryant’s § 2255 petition for lack of proper forum/vehicle and instructed that he must file in the D.C. courts.
The court also denied a certificate of appealability (COA), finding Bryant failed to make a substantial showing of a constitutional right.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper forum/vehicle for collateral attack on D.C. Superior Court conviction	Bryant filed a § 2255 petition in E.D. Va to challenge his D.C. conviction and obtain credit for an unserved sentence	Collateral attack on a D.C. Superior Court conviction must be pursued in the D.C. Superior Court (D.C. Code procedure)	Court dismissed the § 2255 petition as improper in E.D. Va and directed Bryant to litigate in D.C. Superior Court
Certificate of appealability (COA)	Bryant may seek to appeal the district court’s dismissal	No COA should issue because Bryant did not make a substantial showing of the denial of a constitutional right	COA denied; reasonable jurists could not debate the court’s resolution

Garris v. Lindsay, 794 F.2d 722 (D.C. Cir. 1986) (discusses proper collateral procedures for D.C. convictions)
Blair-Bey v. Quick, 151 F.3d 1036 (D.C. Cir. 1998) (challenges to D.C. Superior Court convictions must follow D.C. law)
Slack v. McDaniel, 529 U.S. 473 (2000) (standard for issuing a certificate of appealability)
Barefoot v. Estelle, 463 U.S. 880 (1983) (COA standard context and precedent)