Dennis v. Fallin
677 F. App'x 495
| 10th Cir. | 2017Background
- Plaintiff-appellant Lamarr Raymondo Dennis, a state prisoner appearing pro se, sought declaratory relief under 28 U.S.C. § 2201 challenging Oklahoma sentencing laws and practices.
- Dennis asked the district court to declare: (1) Okla. Stat. tit. 21, § 51.1 (sentence enhancement statute) unconstitutional; (2) Oklahoma’s lack of objective sentencing guidelines violates due process; and (3) the repealed Truth in Sentencing Act should be advisory guidance for constitutionally reasonable punishment.
- The district court dismissed the complaint without prejudice for failure to state a claim, reasoning § 2201 does not independently confer federal jurisdiction and the suit impermissibly attacked a state criminal sentence.
- The district court also refused to construe the filing as a habeas petition because the federal habeas statute of limitations had expired.
- On appeal, Dennis argued the enhancement statute is arbitrary and violative of substantive due process and that broad sentencing ranges without objective guidelines result in unconstitutional arbitrariness.
- The Tenth Circuit reviewed the dismissal de novo and affirmed, concluding declaratory relief cannot be used to shorten or attack a state sentence and that habeas was the exclusive remedy (but time-barred).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 2201 provides an independent basis for federal jurisdiction to challenge state sentencing statutes | Dennis contended he could obtain declaratory relief under § 2201 to invalidate Oklahoma sentencing provisions | Court below argued § 2201 is not an independent grant of federal jurisdiction | Court held § 2201 does not confer independent jurisdiction and cannot be used to attack a state criminal sentence |
| Whether declaratory relief may be used to challenge the validity of a state-court sentence | Dennis argued the enhancement statute and lack of guidelines violate due process, warranting a declaratory judgment | State argued such challenges improperly seek to shorten or invalidate a sentence and are subject to habeas, not declaratory relief | Court held declaratory judgment cannot be used to challenge the fact or duration of confinement; habeas is the exclusive remedy |
| Whether the complaint should be treated as a habeas petition despite pleading as declaratory relief | Dennis implicitly sought relief that would affect his sentence | District court noted habeas claims are time-barred under 28 U.S.C. § 2244(d)(1)(A) | Court declined to convert the complaint to habeas because the statute of limitations had expired |
| Whether dismissal for failure to state a claim was appropriate | Dennis argued his constitutional challenges merited relief | Court relied on jurisdictional and procedural barriers to relief | Court affirmed dismissal for failure to state a claim and deemed the appeal frivolous (strike under 28 U.S.C. § 1915(g)) |
Key Cases Cited
- Casanova v. Ulibarri, 595 F.3d 1120 (10th Cir. 2010) (standard of review for dismissal de novo)
- Devon Energy Prod. Co. v. Mosaic Potash Carlsbad, Inc., 693 F.3d 1195 (10th Cir. 2012) (§ 2201 is not an independent basis for federal jurisdiction)
- Morton v. Avery, 393 F.2d 138 (6th Cir. 1968) (declaratory judgment cannot be used to shorten a sentence or attack a criminal judgment)
- Heck v. Humphrey, 512 U.S. 477 (1994) (habeas corpus is the exclusive remedy for state prisoners challenging the fact or duration of confinement)