Fowler v. Ogle

Summary

The United States District Court for the Middle District of Pennsylvania dismissed StevieRay Fowler’s pretrial habeas petition under 28 U.S.C. § 2241. The court held that Fowler had not shown exhaustion, a special need, or extraordinary circumstances warranting federal intervention in his pending state criminal proceedings. The court also declined to issue a certificate of appealability.

Holdings

1. Petitioners seeking habeas corpus relief prior to final conviction and sentence in state court may only obtain such relief if they make a special showing of need and have exhausted state remedies, or if extraordinary circumstances justify relief.

Questions Presented

1. Whether federal habeas corpus relief under 28 U.S.C. § 2241 is available to challenge pretrial detention pending unresolved state criminal charges

Disposition

dismissed