Medley v. Baltazar
Civil Action No. 2017-1168
| D.D.C. | Jun 26, 2017Background
- Petitioner Louis Medley, III filed a habeas corpus petition and sought leave to proceed in forma pauperis in the Middle District of Pennsylvania.
- Magistrate Judge Carlson granted in forma pauperis status and recommended transfer of the petition to the District of Columbia Superior Court (the sentencing/state forum) pursuant to 28 U.S.C. § 1404(a).
- No party objected to the magistrate judge’s report; the district court nevertheless conducted an independent review for clear error.
- The district court agreed with the recommendation to transfer but concluded § 1404(a) permits transfer only within the federal judiciary, not to a state court.
- The court therefore ordered transfer of the action to the United States District Court for the District of Columbia (which encompasses the Superior Court where Medley was convicted) rather than dismissal.
- The court directed the clerk to transfer the case to the D.D.C. and to close the Middle District of Pennsylvania file.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the petition should be transferred to the sentencing forum | Medley sought transfer to the forum where he was tried and sentenced (D.C. Superior Court) | Respondent did not object; transfer was sought for convenience and justice | Court agreed transfer appropriate but to the federal district court that embraces the sentencing forum (D.D.C.), not to a state court |
| Whether § 1404(a) authorizes transfer to a state court | Implicitly sought transfer to D.C. Superior Court as the proper forum | § 1404(a) limited to transfer within federal courts | Court held § 1404(a) does not authorize transfer to state courts |
| Whether dismissal is required vs. transfer in interests of justice | Transfer preferable to dismissal to preserve petitioner’s claims | No objection; court considered interests of justice | Court ordered transfer to D.D.C. rather than dismissal |
| Whether to adopt magistrate judge’s report absent objections | No objections filed; petitioner relied on magistrate’s recommendation | Court must review for clear error even if no objections | Court adopted report in part after independent review, modifying transferee to D.D.C. |
Key Cases Cited
- Pope v. Atl. Coast Line R. Co., 345 U.S. 379 (U.S. 1953) (§ 1404(a) confines transfer to federal courts)
- Nara v. Frank, 488 F.3d 187 (3d Cir. 2007) (failure to object to magistrate report may forfeit de novo review)
- Henderson v. Carlson, 812 F.2d 874 (3d Cir. 1987) (district court should review dispositive issues despite lack of objections)
- McLaughlin v. Arco Polymers, Inc., 721 F.2d 426 (3d Cir. 1983) (§ 1631 transfer statute applies only within federal courts)
- Utility Lines Const. Servs., Inc. v. HOTI, Inc., 799 F. Supp. 2d 331 (D. Del. 2011) (federal transfer statutes do not permit transfer to state courts)