Hines v. Headley, et al.

Summary

The court denied Mark Anthony Hines's petition for a writ of habeas corpus under 28 U.S.C. § 2254 and dismissed the case without prejudice for failure to exhaust state-court remedies. The court also concluded that Hines's claim for monetary damages was not cognizable in a habeas proceeding and denied a certificate of appealability.

Holdings

1. A § 2254 petitioner must fairly present the substance of his federal claims to the state courts through one complete round of the state's established appellate review process. Because Hines did not raise or pursue either claim through direct review or Alabama Rule 32 proceedings and the required appeals, his claims were unexhausted.
2. Monetary damages are not an available habeas corpus remedy, so Hines's damages claim was legally insufficient on its face.
3. A federal court may summarily dismiss a habeas petition that is legally insufficient on its face; the petition was denied without an evidentiary hearing.

Questions Presented

1. Whether Hines's sentence-related claims were unexhausted because he did not present them through one complete round of Alabama appellate review.
2. Whether monetary damages for alleged unlawful detention and abuse are available through a federal habeas corpus petition.
3. Whether the petition should be dismissed without prejudice without an evidentiary hearing and without issuing a certificate of appealability.

Disposition

dismissed