Tisdale v. Elkton Federal Correctional Institution, 4:17-cv-00530

Petitioner Richard Tisdale, a federal prisoner, filed a pro se "Petition for a Writ of Mandamus" challenging aspects of his 2005 federal conviction and related forfeiture proceedings and alleging misuse of bank records, National Security Letters, and Brady violations.
He asserted numerous claims (14 discrete allegations) including improper evidence handling by Indiana police and FBI, suppression of Brady material, chilling of First Amendment rights by National Security Letters, and alleged failure of appellate filings in the Sixth Circuit.
His primary requested relief was an order directing Elkton Federal Correctional Institution (FCI Elkton) to secure legal research materials for him or to provide a hearing where he could present evidence to the judiciary.
The petition did not identify an independent statutory jurisdictional basis beyond invoking the All Writs Act/mandamus and did not name a respondent authorized to provide the requested relief.
The magistrate judge and district court treated the filings as an attempt to collaterally attack his conviction and noted that such challenges must proceed, if at all, under 28 U.S.C. § 2255 (or § 2241 for execution claims).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus is a proper vehicle to attack a federal conviction	Tisdale sought mandamus relief to obtain evidentiary review/hearing and access to legal research to challenge his conviction	Mandamus cannot substitute for a § 2255 motion; petitioner must use statutory habeas channels to attack conviction	Denied: mandamus is not an alternative to § 2255; petition dismissed
Whether the court had subject-matter jurisdiction over the petition	Tisdale asserted various constitutional and evidentiary violations to invoke the court's power	Court: petitioner failed to establish an independent basis for federal jurisdiction beyond mandamus	Denied for lack of jurisdictional basis; court cannot proceed without proper jurisdiction
Whether FCI Elkton officials can be ordered to hold a criminal evidentiary hearing or secure legal research	Tisdale asked the court to compel prison officials to provide research or conduct a hearing to overturn his conviction	Respondent has no legal authority to conduct a criminal evidentiary hearing or overturn a conviction; prison officials are not proper respondents for such relief	Denied: FCI Elkton officials have no obligation or authority to provide the requested relief
Whether appeal could be taken in good faith	N/A (procedural)	N/A	Court certified that an appeal would not be taken in good faith under 28 U.S.C. § 1915(a)(3)

Preiser v. Rodriguez, 411 U.S. 475 (1973) (when a prisoner challenges the fact or duration of confinement, habeas corpus is the exclusive federal remedy)
Syngenta Crop Protection, Inc. v. Henson, 537 U.S. 28 (2002) (All Writs Act does not create independent federal jurisdiction)
United States v. Peterman, 249 F.3d 458 (6th Cir. 2001) (§ 2255 challenges convictions; § 2241 addresses execution of sentence)
Terrell v. United States, 564 F.3d 442 (6th Cir. 2009) (statutory scheme for federal prisoners seeking habeas relief)
In re Shelton, 295 F.3d 620 (6th Cir. 2002) (courts should not recharacterize pro se filings as § 2255 motions without caution)
Charles v. Chandler, 180 F.3d 753 (6th Cir. 1999) (§ 2255 remedy not inadequate merely because relief is time-barred or successive)
Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998) (a court must dismiss when it lacks subject-matter jurisdiction)
Mississippi Valley Barge Line Co. v. United States, 273 F. Supp. 1 (E.D. Mo. 1967) (courts have inherent and statutory power to enforce judgments)
Ex parte McCardle, 74 U.S. 506 (1868) (when jurisdiction ceases, courts must dismiss the cause)