CAMPBELL v. SUPERINTENDENT, SCI DALLAS
3:25-cv-00101
| W.D. Pa. | Jun 30, 2025Background
- Dwight Campbell filed a federal habeas corpus petition challenging his state conviction and sentence in Pennsylvania (CP-07-CR-1328-2020), after pleading guilty to multiple charges.
- Campbell received a 3-25 year aggregate sentence from Judge Jackie Bernard following guilty pleas in three consolidated cases; a fourth case (CP-07-CR-749-2022) against him remains pending.
- He is simultaneously pursuing post-conviction relief under Pennsylvania’s Post Conviction Relief Act (PCRA) in state court regarding the conviction he challenges here, and an evidentiary hearing was recently held.
- Campbell’s habeas petition also seeks dismissal of the charges in his still-pending criminal case, raising the same arguments as in a separate, pending federal case related to that prosecution.
- The court consolidated Campbell’s multiple claims and found issues of duplicative litigation, improper joinder of claims, and lack of exhaustion of state remedies.
- The petition was screened and denied without a certificate of appealability; Campbell’s separate motion for bail pending decision was denied as moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of state remedies | Campbell claims federal habeas relief is proper | State remedies not yet fully pursued | Petition denied; state process must be exhausted first |
| Joinder of claims from convictions/pending cases | Campbell can challenge both in one petition | It's improper to attack both at once | Can't attack sentences & pending prosecution together |
| Duplicative litigation | Claims are urgent and all should be heard | Already pending in separate case | Duplicate claims must proceed in original case |
| Entitlement to certificate of appealability | See constitutional violations warrant review | Campbell failed to meet standard | No certificate issued; claims not debatable |
Key Cases Cited
- Kiser v. Johnson, 163 F.3d 326 (Habeas Rule 4 allows courts to screen and dismiss meritless habeas petitions before service)
- Magouirk v. Phillips, 144 F.3d 348 (failure to exhaust state remedies may be raised sua sponte)
- Lambert v. Blackwell, 387 F.3d 210 (exhaustion doctrine requires presenting federal claims to state court)
- Miller-El v. Cockrell, 537 U.S. 322 (standard for granting a certificate of appealability)
- Slack v. McDaniel, 529 U.S. 473 (certificate of appealability standard on procedural dismissals)