Anton Andreyevich Iagounov v. Warden John Mattos, et al.

Summary

The United States District Court for the Middle District of Tennessee addresses a federal pretrial detainee’s petition for habeas corpus under 28 U.S.C. § 2241. The court concludes that jurisdiction lies in the District of Nevada, where the petitioner is confined and where his immediate custodian and underlying criminal proceedings are located. The court grants the respondent’s motion insofar as it directs transfer of the petition to the District of Nevada under 28 U.S.C. § 1631.

Holdings

1. For a challenge to present physical confinement, the proper respondent is the petitioner's immediate custodian, and jurisdiction lies only in the federal district where the petitioner is confined. Because Petitioner was confined in Nevada and Warden Mattos was located there, the Middle District of Tennessee lacked jurisdiction.
2. When a federal court lacks jurisdiction, transfer under 28 U.S.C. § 1631 is appropriate if transfer is in the interest of justice. Under the circumstances, transfer of the petition to the District of Nevada was preferable to dismissal.

Questions Presented

1. Whether a § 2241 petition challenging present physical confinement may be heard in a district other than the district where the petitioner is confined and where the immediate custodian is located.
2. Whether the petition should be dismissed without prejudice or transferred under 28 U.S.C. § 1631 when the court lacks jurisdiction.

Disposition

other