McHenry v. Payne

United States District Court for the Eastern District of Arkansas, Northern Division · July 7, 2025 · No. 3:23-cv-00239

Summary

This United States District Court order addresses a pro se habeas petition challenging the computation of the petitioner's federal and state prison sentences. The court notes that while the respondent argues the claim is not cognizable because it relies solely on state law, the court raises sua sponte the threshold issue of whether the petitioner exhausted available state judicial remedies. The court grants the petitioner until August 8, 2025, to file a brief explaining why the petition should not be dismissed without prejudice for failure to exhaust state remedies.

Court
United States District Court for the Eastern District of Arkansas, Northern Division
Jurisdiction
United States District Court for the Eastern District of Arkansas, Northern Division
Decision date
July 7, 2025
Docket number
3:23-cv-00239
Procedural posture
Petitioner filed a habeas corpus petition in this court; the district court denied a motion for clarification and now orders briefing on exhaustion of state remedies.
Precedential value
nonprecedential
Parties
Markelvin Lorenzo McHenry v. Dexter Payne
Disposition
other

Topics

federal habeas corpuspost-conviction reliefhabeas corpus

Practice areas

criminal procedure

Questions Presented

  1. Whether a federal habeas petitioner must exhaust available state judicial remedies before seeking relief under 28 U.S.C. §2254(b).

Key quotations

The exhaustion of state remedies is an express requirement of federal habeas corpus relief under 28 U.S.C. 2254(b).
The Court would like to hear from McHenry on the exhaustion question.

Factual background

McHenry was sentenced to a 165‑month federal term and a 276‑month state term that run consecutively to each other. He challenged the computation of his state sentence and later sought federal habeas relief, arguing the federal sentence should be coordinated with the state sentence.

Procedural history

McHenry pleaded guilty to federal and state offenses, received concurrent and consecutive sentences, filed administrative grievances in Arkansas, and then filed a federal habeas petition. The court denied his motion for clarification and now requires briefing on whether he exhausted state judicial remedies.

Remand instructions

Petitioner is ordered to file a short brief on or before August 8, 2025 addressing why the case should not be dismissed for failure to exhaust state judicial remedies.

Court Document

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