GONZALEZ v. WARDEN FCI MCKEAN
1:24-cv-00022
W.D. Pa.May 16, 2025Background
- William Gonzalez was convicted in the Southern District of New York and sentenced to 17 years in prison with five years of supervised release for conspiracy to distribute controlled substances, in violation of 21 U.S.C. § 846.
- Gonzalez is currently incarcerated at FCI McKean in Bradford, Pennsylvania.
- He filed a habeas corpus petition under 28 U.S.C. § 2241 in the Western District of Pennsylvania, seeking to vacate his conviction and sentence based on alleged ineffective assistance of counsel and sentencing errors.
- The case was referred to Chief Magistrate Judge Lanzillo for a report and recommendation (R&R).
- Judge Lanzillo recommended transferring the case to the Southern District of New York under 28 U.S.C. § 1404, noting this court lacks § 2241 jurisdiction and that the sentencing court is better positioned to address the claims.
- No objections to the R&R were filed, and the district judge ordered the case transferred and closed in the Western District of Pennsylvania.
Issues
| Issue | Gonzalez's Argument | Warden's Argument | Held |
|---|---|---|---|
| Jurisdiction under § 2241 | Habeas relief proper for wrongful conviction and sentence due to counsel and court errors | § 2241 not appropriate for challenging conviction/sentence | Court lacks § 2241 jurisdiction solidified; transfer recommended |
| Proper Court for Review | The Pennsylvania court should grant relief | Claims should be addressed by sentencing court | Sentencing court (Southern District of New York) is proper venue |
| Remedy under § 2255 | Claims not stated explicitly in filing, but implied alternative relief | Petitioner has potential remedy under § 2255 | Claims may be brought under § 2255 before the sentencing court |
| Transfer in Interests of Justice | Not expressly argued | Requested transfer if court lacked jurisdiction | Transfer to appropriate venue ordered in interests of justice |
Key Cases Cited
No precedential cases with official reporter citations are referenced in the opinion.
