Dakota Keller v. Judge Kelley, Aaron Jones, and Scott Schmidt

Summary

The court dismissed Dakota Keller’s petition for a writ of mandamus challenging his Illinois state-court sentence. It held that 28 U.S.C. §§ 1361 and 1651 do not authorize federal mandamus relief against state officials and that the court therefore lacked subject-matter jurisdiction. The dismissal was not counted as a strike under 28 U.S.C. § 1915(g) and did not preclude Keller from pursuing relief in state court or another appropriate forum.

Holdings

1. Neither 28 U.S.C. § 1361 nor 28 U.S.C. § 1651 authorizes a federal court to issue a writ of mandamus against state officials.
2. The district court lacked subject matter jurisdiction over Keller's petition for mandamus challenging actions by Illinois state officials, and the petition was dismissed.

Questions Presented

1. Whether a federal district court may issue a writ of mandamus under 28 U.S.C. §§ 1361 or 1651 against state judicial and state-court officials.
2. Whether the district court had subject matter jurisdiction over Keller's petition challenging his state-court sentence.

Disposition

dismissed