William R. Jackson v. Warden Gregory Sampson

Summary

The court overrules William R. Jackson’s objection to a magistrate judge’s order concerning his motion to strike the respondent’s answer and request for a hearing. Applying the clearly erroneous or contrary-to-law standard under 28 U.S.C. § 636(b)(1)(A), the court finds no error in directing the respondent to resend the answer and supporting exhibits and explains that default judgment is unavailable in federal habeas corpus proceedings.

Holdings

1. A district court may disturb a magistrate judge's ruling on a non-dispositive motion only when the ruling is clearly erroneous or contrary to law.
2. The magistrate judge did not clearly err by finding that Respondent mailed Jackson's copy of the answer and supporting exhibits to a previous address and directing Respondent to resend them.
3. Jackson's arguments that Respondent could not refute grounds in his petition did not establish procedural unfairness or require an evidentiary hearing; those arguments could be raised in his reply.
4. Default judgment is not an available remedy in a federal habeas corpus case merely because the respondent fails to answer.

Questions Presented

1. Whether the magistrate judge's order concerning the mailing of Respondent's answer and supporting exhibits was clearly erroneous or contrary to law.
2. Whether Jackson's disagreement with the substance of Respondent's answer required an evidentiary hearing or demonstrated procedural unfairness.
3. Whether Respondent's failure to mail the answer to Jackson's current address constituted perjury, fraud, or other reversible misconduct.
4. Whether default judgment is available as a remedy in a federal habeas corpus proceeding if the respondent fails to answer.

Disposition

other