God Knows Imashe aka Wallace Mitchell v. J. Wadas

Summary

The United States District Court for the Southern District of Indiana dismissed God Knows Imashe aka Wallace Mitchell’s 28 U.S.C. § 2241 habeas petition for lack of jurisdiction. The court held that Mitchell’s challenge to the Bureau of Prisons’ refusal to recognize his lawful name concerned neither the fact nor duration of confinement nor a quantum change in custody, and therefore could not be pursued through habeas corpus. The court also denied several related motions and granted leave to amend the respondent in the case caption.

Holdings

1. A § 2241 habeas petition is not an appropriate vehicle for claims that do not challenge the fact or duration of confinement or seek a quantum change in the level of custody. Mitchell's identity and name-recognition claims therefore could not be brought in this habeas case, and the petition was dismissed for lack of jurisdiction.
2. The court denied the mandamus and show-cause motions because Mitchell had not filed a proper § 2241 petition and the court could not grant the relief sought in the habeas action.
3. The motion to amend the caption was granted, and the clerk was directed to reflect B. Lammer as the respondent.

Questions Presented

1. Whether Mitchell's challenge to the Bureau of Prisons' failure to verify his identity and recognize his lawful name is cognizable under 28 U.S.C. § 2241.
2. Whether the court could grant the requested mandamus and show-cause relief in the § 2241 action.
3. Whether the case caption should be amended to substitute B. Lammer as respondent.

Disposition

dismissed