Jose Matamoros v. Greg Grams
2013 U.S. App. LEXIS 1965
| 7th Cir. | 2013Background
- Matamoros was sentenced in 1983 to two consecutive five-year terms with a three-year special parole term to follow.
- The ordinary parole term expired in 2005; Matamoros received a Notice of Discharge stating he was no longer under supervision.
- The special parole term was not communicated to Matamoros and a Certificate of Special Parole, nunc pro tunc, was issued about six hours after the discharge notice.
- On September 9, 2005, Matamoros engaged in armed robbery, triggering a parole violation arrest warrant for the special parole term.
- The Commission later lodged a detainer based on the warrant, and Matamoros challenged the detainer as illegal and sought habeas relief.
- The district court denied relief, and the Seventh Circuit affirmed, holding no due process violation or equitable estoppel here.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of notice for the special parole term | Matamoros lacked adequate notice | Notice was adequate via multiple documents and statutes | No due process violation; adequate notice established |
| Timeliness of dispositional review of the detainer | Delay harmed Matamoros | No constitutional violation absent prejudice | No due process violation from delay; no prejudice shown |
| Equitable estoppel against the government | Notice mistake should estop enforcement | No affirmative misconduct; record shows negligence | Estoppel not warranted; no equitable estoppel against government |
Key Cases Cited
- United States v. Batchelder, 442 U.S. 114 (1979) (interpretation of notice under clearly defined conduct and punishment)
- Moody v. Daggett, 429 U.S. 78 (1976) (detainer hearing delay; not a constitutional violation absent prejudice)
- Fazzini v. United States, 414 F.3d 695 (7th Cir. 2005) (parole context; framework for due process in release and supervision)