Matthew Tucker v.
683 F. App'x 166
| 3rd Cir. | 2017Background
- Matthew Tucker has been civilly committed in New Jersey psychiatric facilities intermittently since an insanity acquittal for a 1989 murder; he remains committed under more recent orders.
- Tucker is a prolific pro se litigant who has filed numerous district-court actions and appeals challenging his commitment and other matters.
- He submitted an almost entirely illegible handwritten filing to this Court, docketed as a petition for a writ of mandamus.
- The petition does not clearly identify a district-court ruling or other target of mandamus, and the court could not discern a viable mandamus claim from the filing.
- The panel granted Tucker leave to supplement but denied the mandamus petition and any other relief requested; it advised Tucker to file legible, preferably typewritten, submissions in the future.
- The opinion notes that habeas relief challenging commitment typically must start in the district court, and the panel expressed no view on the merits of any commitment challenge Tucker might file there.
Issues
| Issue | Tucker's Argument | Respondent's Argument | Held |
|---|---|---|---|
| Whether mandamus to compel district-court action is warranted | Tucker seeks relief (handwritten petition) — appears to challenge court docketing or commitment proceedings | No clear target; district court has discretion over docket management; mandamus inappropriate | Denied — no discernible basis for mandamus relief |
| Whether the Court may adjudicate a challenge to civil commitment on mandamus | Tucker appears to seek immediate release and claims double jeopardy and statutory arguments | Mandamus is not the proper first-instrument to obtain habeas-style relief; jurisdictional limits apply | Denied — habeas-type challenges must proceed in district court first |
| Whether illegibility of filings justifies dismissal or other remedy | Tucker submitted largely illegible pleadings | Court noted repeated illegibility; prior dismissals without prejudice and admonitions given | Court admonished Tucker to file typewritten or legible submissions; denied relief but granted leave to supplement |
| Whether any other relief requested in filings should be granted | Tucker’s papers ambiguous, possibly referencing state-court 2016 proceedings and NJ statutes | No clear articulation of relief; existing procedures for habeas and commitment challenges remain | All other requested relief denied; no opinion on merits of any proper district-court habeas challenge |
Key Cases Cited
- United States v. Higdon, 638 F.3d 233 (3d Cir. 2011) (describing traditional scope of the writ of mandamus)
- In re Fine Paper Antitrust Litig., 685 F.2d 810 (3d Cir. 1982) (district-court docket management and mandamus standards)
- United States v. Brooks, 245 F.3d 291 (3d Cir. 2001) (jurisdictional considerations for initial habeas filings)
- In re Tucker, [citation="598 F. App'x 813"] (3d Cir. 2015) (noting Tucker’s illegible filings)