LOGAN
v.
SECRETARY, WARDEN, FCC COLEMAN II
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The court held that it lacked jurisdiction to review the petitioner's claims, as they constituted a direct attack on a District of Columbia appellate court decision, which is beyond the scope of federal district court review.
Petitioner, serving a life sentence, filed a federal habeas petition after his motion for rehearing was denied by the D.C. Court of Appeals. The Distr…
The full statement of facts, procedural history, and disposition for this case are member content.
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OPINION AND ORDER1
Before the Court is Petitioner Keith Logan’s Motion for Relief Pursuant to Federal Rules of Civil Procedure Rule 60(b)(4) and 60(b)(6) (Doc. 6). Logan is serving a life sentence in federal prison following a conviction in the Superior Court of the District of Columbia. He filed a federal habeas petition under 28 U.S.C. § 2254, arguing the District of Columbia Court of Appeals violated his due process rights in denying his motion for rehearing. (Doc. 1). The Court dismissed the Petition under D.C. Code § 23-110, which strips federal courts of jurisdiction over habeas claims absent a showing that § 23-110 is inadequate
Logan argues he cannot collaterally attack the appellate court decision in a § 23-110 action, and that is true. § 23-110 does not give the D.C. Superior Court authority to review appellate proceedings. Williams v. Martinez, 586 F. 3d 995, 998-99 (D.C. Cir. 2009). Thus, § 23-110 does not bar this action. But this Court still lacks jurisdiction to consider Logan’s Petition. Although Logan frames his argument as a collateral attack based on due process, it is instead a direct attack that must be raised at the next level of appellate review. Logan takes issue with the “factual findings” of the D.C. Court of
Appeals.2 He asks this Court to “review the record do novo to determine if the factual findings of the DCCA were fairly supported by the evidence presented.” (Doc. 1 at 52). That is “beyond this Court’s jurisdiction because ‘the United States District Court is without authority to review final determinations of the
District of Columbia Court of Appeals in judicial proceedings.’” Waters v. Lockett, 956 F. Supp. 2d 109, 113 (D.D.C. 2013) (quoting District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 476 (1983)). “Such is the exclusive province of the Supreme Court[.]” Id.; see also 28 U.S.C. § 1257.
UNITED STATES DISTRICT JUDGE
SA: FTMP-1 Copies: All Parties of Record The Clerk of the Eleventh Circuit Court of Appeals
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979)
- Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983)
- United States v. Barton, 909 F.3d 1323 (11th Cir. 2018)