Carrington v. Trump

Summary

The United States District Court for the District of Columbia granted the plaintiff's application to proceed in forma pauperis but dismissed the complaint without prejudice for lack of subject matter jurisdiction. The court held that the plaintiff failed to allege an injury sufficient to establish Article III standing and explained that his request for release from custody had to be pursued in a habeas action against the proper custodian in the appropriate jurisdiction.

Holdings

1. Plaintiff failed to allege facts establishing that he suffered or was likely to suffer an injury resulting from any defendant's conduct; therefore, he lacked Article III standing and the court lacked subject matter jurisdiction.
2. The district court could not entertain plaintiff's request for release from custody because a habeas petition challenging present physical custody must name the custodian as respondent, and the custodian must be within the court's territorial jurisdiction.

Questions Presented

1. Whether plaintiff alleged facts sufficient to establish Article III standing and subject matter jurisdiction.
2. Whether the district court was the proper forum for plaintiff's request for release from custody under habeas corpus.

Disposition

dismissed