Willie-Frank Walker v. State of Florida
688 F. App'x 864
11th Cir.2017Background
- Plaintiff Willie-Frank Walker, a pro se Florida prisoner, filed a complaint in federal district court challenging aspects of his confinement.
- The State moved to dismiss; the district court granted dismissal under Fed. R. Civ. P. 12(b)(6) for failure to state a claim.
- Walker appealed, arguing the district court erred by dismissing for lack of subject-matter jurisdiction and claiming federal-question jurisdiction.
- The district court’s dismissal was on the merits (Rule 12(b)(6)), not on subject-matter jurisdiction; neither the order nor the State’s motion referenced jurisdictional dismissal.
- Walker did not identify the legal claim he sought to plead on appeal and raised arguments resembling rejected “sovereign citizen” theories.
- The panel considered that challenges to the fact or duration of confinement must be pursued by habeas corpus, not by ordinary civil complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court dismissed for lack of subject-matter jurisdiction | Walker contends the court erred and that federal-question jurisdiction exists | The State and record show dismissal was for failure to state a claim under Rule 12(b)(6), not jurisdictional | Court: No jurisdictional dismissal occurred; Walker’s characterization is incorrect |
| Whether dismissal under Rule 12(b)(6) was erroneous | Walker did not meaningfully dispute the Rule 12(b)(6) dismissal on appeal | District court found complaint lacked factual allegations meeting Rule 8/Twombly/Iqbal pleading standards | Court: Walker abandoned challenge to the Rule 12(b)(6) dismissal; dismissal stands |
| Whether Walker’s arguments implicate sovereign-citizen or frivolous theories | Walker advanced arguments similar to sovereign-citizen claims | Government treats those theories as frivolous and previously rejected | Court: Such sovereign-citizen-style arguments are frivolous and insufficient |
| Whether relief should have been via habeas corpus | Walker sought relief affecting his confinement without pursuing habeas | State treats the proper remedy as habeas corpus for challenges to confinement | Court: If Walker sought relief as to legality/duration of detention, habeas was required (Preiser) |
Key Cases Cited
- Nicholson v. Shafe, 558 F.3d 1266 (11th Cir. 2009) (standard of review for subject-matter jurisdiction dismissals)
- Hill v. White, 321 F.3d 1334 (11th Cir. 2003) (de novo review of Rule 12(b)(6) dismissals and treating allegations as true)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plaintiff must plead more than labels and conclusions to survive Rule 12(b)(6))
- Oxford Asset Mgmt., Ltd. v. Jaharis, 297 F.3d 1182 (11th Cir. 2002) (conclusory allegations and legal conclusions insufficient to avoid dismissal)
- Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014) (issues not plainly and prominently argued on appeal are abandoned)
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas corpus is the exclusive federal remedy for challenges to fact or duration of confinement)
- United States v. Sterling, 738 F.3d 228 (11th Cir. 2013) (rejection of sovereign-citizen arguments as frivolous)
AFFIRMED.