Michael A. Reed v. Warden

Summary

The United States District Court for the Central District of California dismissed Michael A. Reed’s pro se petition for a writ of mandamus. The court held that federal district courts lack jurisdiction to issue mandamus compelling state courts or state judicial officers, and further concluded that the requested relief was not cognizable under 28 U.S.C. § 2254.

Holdings

1. The federal mandamus statute gives federal district courts original jurisdiction only to compel an officer or employee of the United States or a federal agency to perform a duty owed to the plaintiff; it does not authorize mandamus against state courts or state judicial officers.
2. A prisoner petition proceeding in forma pauperis may be dismissed as frivolous when it lacks an arguable basis in law or fact, and Reed's federal mandamus petition met that standard because the requested relief was beyond the court's jurisdiction.
3. Construing the filing as a petition under 28 U.S.C. § 2254 would not provide a basis for relief because an order compelling a state superior court to allow self-representation would not fall within the core of habeas corpus or result in immediate or earlier release from confinement.

Questions Presented

1. Whether a federal district court has authority under the federal mandamus statute to compel a state superior court or state judicial officer to permit a state prisoner to represent himself.
2. Whether the requested coercive order falls within the core of federal habeas corpus under 28 U.S.C. § 2254.
3. Whether the petition was frivolous and subject to dismissal under 28 U.S.C. §§ 1915A and 1915(e)(2)(B).

Disposition

dismissed