Michael Reynolds v.
706 F. App'x 98
| 3rd Cir. | 2017Background
- Reynolds was convicted in 2007 in the Middle District of Pennsylvania of terrorism-related offenses and sentenced to 360 months; this Court affirmed and the Supreme Court denied certiorari.
- Reynolds filed multiple pro se collateral challenges (§ 2255 and § 2241) and appeals; district and circuit courts repeatedly denied relief and denied leave to file successive § 2255 motions.
- In 2017 Reynolds sought mandamus from this Court, arguing Haskell (failure to correct perjured testimony) entitled him to relief from his conviction.
- The Clerk initially dismissed Reynolds’ mandamus petition for failure to prosecute; Reynolds moved for reconsideration and also sought to compel FOIA compliance from the U.S. Attorney’s Office.
- The Court considered whether mandamus was appropriate given existing § 2255 procedures, prior denials, and ongoing district-court proceedings on Reynolds’ later filings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus can be used to obtain relief from Reynolds’ conviction based on Haskell | Reynolds: Haskell requires relief because prosecution failed to correct perjured testimony at his trial | Government: Collateral relief must proceed via § 2255; mandamus is not an alternative to the statutory scheme | Denied — mandamus is not the proper vehicle; § 2255 is the proper avenue |
| Whether mandamus is appropriate because district court delay or docket management has denied relief | Reynolds: District court’s delay in acting on postconviction filings warrants mandamus | Government: Court docket management is discretionary; delay alone does not create a clear right to mandamus | Denied — no clear, indisputable right to have the district court act faster |
| Whether inability to meet § 2255 gatekeeping makes mandamus or § 2241 available | Reynolds: Gatekeeping prevents effective § 2255 relief, so other remedies are needed | Government: Failure to meet § 2244 gatekeeping does not make mandamus or § 2241 available; Dorsainvil controls | Denied — inability to satisfy successive‑motion rules is not an extraordinary circumstance justifying mandamus |
Key Cases Cited
- Haskell v. Superintendent Greene SCI, 866 F.3d 139 (3d Cir. 2017) (granting habeas where prosecution failed to correct perjured testimony)
- In re Diet Drugs Prods. Liab. Litig., 418 F.3d 372 (3d Cir. 2005) (mandamus is a drastic remedy for extraordinary cases)
- Hollingsworth v. Perry, 558 U.S. 183 (2010) (mandamus standards and requirements)
- In re Dorsainvil, 119 F.3d 245 (3d Cir. 1997) (§ 2255 is the primary remedy for collateral challenges; restrictions on successive motions)
- Massey v. United States, 581 F.3d 172 (3d Cir. 2009) (gatekeeping limits do not create extraordinary circumstances for mandamus)