Willis T. Jackson v. Scotty Bodiford

Summary

The United States District Court for the District of South Carolina adopted the magistrate judge’s Report and Recommendation and dismissed Willis T. Jackson’s pro se 28 U.S.C. § 2241 habeas petition based on failure to exhaust state remedies and abstention under Younger v. Harris. The court reviewed the unobjected-to Report for clear error and denied a certificate of appealability.

Holdings

1. When a party files no timely specific objection to a magistrate judge's report and recommendation, the district court need not conduct de novo review and instead must determine whether the report contains clear error on the face of the record.
2. The petition was dismissed on procedural grounds because Jackson's claims were unexhausted and federal intervention was barred by Younger v. Harris; the dismissal was without prejudice to the extent stated by the court and was not a merits determination.
3. A certificate of appealability would not issue because Jackson failed to satisfy the applicable substantial-showing standard for relief denied on procedural grounds.

Questions Presented

1. Whether the district court should review the unobjected-to report and recommendation for clear error.
2. Whether the § 2241 petition should be dismissed because the claims were unexhausted and federal intervention was barred by Younger v. Harris.
3. Whether a certificate of appealability should issue.

Disposition

dismissed