Ransom v. United States District Court for the District of Columbia, Civil Action No. 2017-0375

Pro se petitioner Joseph Ransom filed a habeas petition seeking release, damages, and a declaration that Public Law 80-772 (1947) is unconstitutional, asserting his conviction arose under that law passed without a constitutional quorum.
Ransom contends a federal district court lacked jurisdiction over his trial and imprisonment in Colorado because of the alleged defect in Public Law 80-772.
He requests immediate release, a declaration of innocence, $3,500 per day for illegal incarceration, and a tax exemption on that award.
The Government and the Court treat the filing as an attempt to challenge the validity of the conviction and the jurisdictional statute.
The Court observed Ransom did not show this district imposed his sentence, nor that a §2255 motion in the sentencing court would be inadequate or ineffective to test his detention.
The Court found Ransom’s statutory-quorum theory frivolous, noted prior uniform dismissals of identical claims, and determined damages claims barred under Heck because his conviction has not been invalidated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper forum to challenge federal conviction	Ransom brought habeas/damages here asserting the statute voids the sentencing court’s jurisdiction	The Court (respondent) notes petitioner failed to show this district imposed the sentence or that §2255 in the sentencing court is inadequate	Dismissed for lack of showing this is the correct forum and because §2255 is the proper vehicle absent a showing of inadequacy
Proper procedural vehicle (§2255 exclusivity)	Ransom sought relief via habeas/damages rather than §2255 motion	Courts hold §2255 is the exclusive means to challenge a federal sentence’s legality unless §2255 is inadequate	Petition dismissed because §2255 is the exclusive remedy and Ransom did not show §2255 inadequate
Validity of Public Law 80‑772 (quorum theory)	Ransom argues the statute was not lawfully enacted and therefore courts lacked jurisdiction	The Court treats the quorum theory as a baseless, widely rejected “jailhouse” claim, pointing to numerous dismissals	Held frivolous and without merit; claim dismissed
Damages for unconstitutional conviction/imprisonment	Ransom seeks monetary damages for illegal confinement	Under Heck, damages barred unless conviction/sentence has been invalidated	Damages claim dismissed because conviction has not been reversed or invalidated

Stephens v. Herrera, 464 F.3d 895 (9th Cir. 2006) (§2255 is the exclusive vehicle to challenge federal sentence legality)
Taylor v. U.S. Bd. of Parole, 194 F.2d 882 (D.C. Cir. 1952) (attack on statute under which defendant was convicted should be pursued under §2255)
Cardenas‑Celestino v. United States, 552 F. Supp. 2d 962 (W.D. Mo. 2008) (collecting dismissals of identical quorum theory claims as frivolous)
Heck v. Humphrey, 512 U.S. 477 (1994) (damages for unconstitutional conviction barred unless conviction reversed/invalidated)
Johnson v. Williams, 699 F. Supp. 2d 159 (D.D.C. 2010) (applying Heck to dismiss damages claim where conviction not invalidated)