United States v. Samuel Knowles
683 F. App'x 736
| 11th Cir. | 2017Background
- Samuel Knowles, proceeding pro se, sought declaratory relief under 28 U.S.C. § 2201 to vacate his 2008 conviction and 420-month sentence for cocaine conspiracy, arguing the district court lacked personal jurisdiction because his 2006 extradition from the Bahamas violated the Extradition Treaty, international law, and the Constitution.
- On direct appeal of his 2008 conviction, this Court rejected Knowles’s extradition challenge in United States v. Knowles, 390 F. App’x 915 (11th Cir. 2010).
- Knowles later filed a § 2255 motion in 2011 raising ineffective-assistance claims, which the district court denied; he did not obtain appellate authorization to file a successive § 2255 motion after that.
- In 2016 Knowles filed the pro se declaratory judgment action seeking vacatur of his conviction and sentence; the district court dismissed for lack of jurisdiction.
- On appeal, Knowles argued the district court lacked personal jurisdiction in the criminal case due to improper extradition; the panel reviewed jurisdiction de novo and affirmed the dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 2201 supplies jurisdiction to challenge a federal criminal judgment | Knowles: § 2201 allows declaratory action to vacate conviction for lack of jurisdiction | Government: § 2201 does not confer jurisdiction; relief challenging conviction must be via § 2255 | Court: § 2201 does not confer jurisdiction; substantive collateral attack must be brought under § 2255 |
| Whether Knowles’s claim is cognizable as a non-successive collateral challenge | Knowles: Claim alleges lack of jurisdiction, not a § 2255 claim, so no authorization needed | Government: Substance seeks vacatur of conviction/sentence — a successive § 2255 in substance — requiring appellate authorization | Court: Although styled under § 2201, the claim attacks conviction/sentence and is a successive § 2255; Knowles lacked prior authorization, so district court lacked jurisdiction |
| Whether extradition-based challenge raises subject-matter jurisdiction (non-waivable) | Knowles: Extradition defect means lack of jurisdiction, which cannot be waived, so federal courts must hear it | Government: Extradition relates to personal jurisdiction, which can be waived; procedural successive-motions rules apply | Court: Extradition implicates personal, not subject-matter, jurisdiction; objections to personal jurisdiction can be waived, so Knowles cannot avoid § 2255 restrictions |
| Whether the district court had jurisdiction to entertain the declaratory action | Knowles: District court should resolve the jurisdictional defect via declaratory judgment | Government: District court lacked jurisdiction because § 2201 is not an independent jurisdictional basis and Knowles failed to get § 2255 authorization | Court: Affirmed dismissal for lack of jurisdiction; district court lacked power to hear the successive collateral attack |
Key Cases Cited
- United States v. Knowles, 390 F. App’x 915 (11th Cir. 2010) (earlier decision rejecting Knowles’s extradition challenge on direct appeal)
- Stuart Weitzman, LLC v. Microcomputer Resources, Inc., 542 F.3d 859 (11th Cir. 2008) (Declaratory Judgment Act does not itself confer federal jurisdiction)
- Household Bank v. JFS Grp., 320 F.3d 1249 (11th Cir. 2003) (role of declaratory relief in precipitating suits)
- Darby v. Hawk-Sawyer, 405 F.3d 942 (11th Cir. 2005) (collateral attacks on federal sentences must normally proceed under § 2255)
- United States v. Oliver, 148 F.3d 1274 (11th Cir. 1998) (standard of de novo review for jurisdictional questions)
- United States v. Isaac Marquez, 594 F.3d 855 (11th Cir. 2010) (extradition is a means to obtain personal jurisdiction; personal-jurisdiction objections can be waived)
- United States v. Holt, 417 F.3d 1172 (11th Cir. 2005) (district court lacks jurisdiction to consider successive § 2255 without appellate authorization)