Steven Johnson v., 688 F. App'x 118

Steven A. Johnson, a federal prisoner, filed ten federal habeas corpus petitions (eight in the District Court, two transferred in).
Johnson complained the District Court had not ruled on most of his filings and sought writs of mandamus in this Court to force rulings.
Mandamus requires no adequate alternative remedy and a clear and indisputable right to relief; it is an extraordinary remedy.
The Third Circuit reviewed the District Court docket and found active case management: several petitions were dismissed, some dismissals were vacated and the government was ordered to respond, one petition was transferred, and others were pending with timely action.
The Court concluded no extraordinary delay or refusal to exercise jurisdiction existed and declined to micromanage the District Court docket.
The Third Circuit denied Johnson’s mandamus petitions but granted several procedural requests (filing of prison account statement, IFP status, waiver of certain service requirements).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus should issue to compel the District Court to rule on Johnson’s filings	District Court failed to rule on the majority of his filings; undue delay tantamount to failure to exercise jurisdiction	District Court actively adjudicated many petitions, ordered responses, transferred a case, and vacated dismissals when appropriate	Denied — no extraordinary delay or failure to exercise jurisdiction; mandamus is not warranted
Whether Johnson lacks any adequate alternative remedy	Johnson argues mandamus is his only way to obtain rulings	Respondent shows District Court is addressing cases through normal docket procedures	Denied — petitioner failed to show lack of adequate alternative means
Whether the right to issuance of the writ is clear and indisputable	Johnson contends his right to prompt rulings is clear	Court finds no clear, indisputable right given active case processing	Denied — right to issuance not clear and indisputable
Whether appellate court should micromanage district docket to expedite rulings	Johnson seeks direct intervention to force rulings	Court cautions against micromanaging district courts’ dockets absent extraordinary circumstances	Denied — appellate court will not micromanage docket

Kerr v. U.S. Dist. Court, 426 U.S. 394 (establishes mandamus as an extraordinary remedy)
Madden v. Myers, 102 F.3d 74 (3d Cir. 1996) (mandamus requires no other adequate means and a clear, indisputable right)
Lacey v. Cessna Aircraft Co., 932 F.2d 170 (3d Cir. 1991) (court will not micromanage a district court’s docket)