Rolando Rodriguez-Flores, et al. v. Leonard Oddo, et al.

Summary

The Southern District of West Virginia granted the Government’s motion to transfer a habeas corpus action concerning an immigration detainee. Applying Rumsfeld v. Padilla, the court held that jurisdiction for a challenge to present confinement lies in the district of confinement, which was the Western District of Pennsylvania when the petition was filed. The court rejected an asserted bad-faith-transfer exception and directed the Clerk to transfer the action.

Holdings

1. Under the bright-line rule for habeas challenges to present confinement, jurisdiction lies in the district of confinement, so the Southern District of West Virginia lacked jurisdiction because Petitioner was confined in the Western District of Pennsylvania when he filed the petition.
2. When the court lacks jurisdiction but the action could have been brought in another federal court, transfer to that court is appropriate under 28 U.S.C. § 1631 when transfer is in the interest of justice.

Questions Presented

1. Whether the Southern District of West Virginia had jurisdiction over a habeas petition challenging present confinement when the petitioner was physically confined in the Western District of Pennsylvania at the time of filing.
2. Whether the court should transfer the action under 28 U.S.C. § 1631 rather than dismiss it for lack of jurisdiction.

Disposition

other