Eric Rodney Hill v. E. Rickard

Summary

The U.S. District Court for the District of Columbia dismissed a habeas petition challenging a D.C. Superior Court conviction. The court held that 28 U.S.C. § 2254 relief was unavailable because the petitioner could pursue relief under D.C. Code § 23-110, and the local remedy was not inadequate or ineffective.

Holdings

1. Under D.C. Code § 23-110(g), a federal court may not entertain a habeas petition by a District of Columbia prisoner who could seek relief through a motion under § 23-110(a), unless the local remedy is inadequate or ineffective to test the legality of the detention.
2. The District Court lacked jurisdiction to entertain the petition because Petitioner's claims were available locally under D.C. Code § 23-110(a).

Questions Presented

1. Whether a federal court may entertain a habeas petition by a District of Columbia prisoner challenging a District of Columbia Superior Court conviction when the asserted claims are available through a motion under D.C. Code § 23-110(a).
2. Whether the availability of the local § 23-110 remedy deprived the District Court of jurisdiction over the petition.

Disposition

dismissed