Dwight Campbell v. Superintendent S.C.I. Dallas, et al.

Summary

The United States District Court for the Western District of Pennsylvania adopted a magistrate judge’s Report and Recommendation and denied Dwight Andre Campbell’s habeas corpus petition under 28 U.S.C. § 2254. The court held that the petition was barred as an abuse of the writ, while the parole-eligibility claim was unexhausted, and it overruled Campbell’s objections. The court dismissed pending motions as moot, denied a certificate of appealability, and directed the clerk to close the case.

Holdings

1. The district court had jurisdiction to entertain Campbell's applications for state habeas relief under 28 U.S.C. §§ 2241 and 2254.
2. A district court need not obtain a habeas petitioner's consent before referring the matter to a magistrate judge for a report and recommendation.
3. The petition was subject to denial under the abuse-of-the-writ doctrine because Campbell's related petitions raised claims that had already been adjudicated on the merits; a prior trial is not required for the doctrine to apply.
4. Campbell's claim that he had reached parole eligibility but had not received a parole hearing was unexhausted and could not provide a basis for federal habeas relief.
5. New allegations raised for the first time in objections to a magistrate judge's Report and Recommendation were not properly before the district court.
6. A certificate of appealability was denied because Campbell did not make a substantial showing of the denial of a constitutional right or show that reasonable jurists would debate the court's assessment.

Questions Presented

1. Whether the district court had jurisdiction over Campbell's state habeas applications under 28 U.S.C. §§ 2241 and 2254.
2. Whether the district court was required to obtain Campbell's consent before referring the habeas matter to a magistrate judge.
3. Whether Campbell's petition was barred by the abuse-of-the-writ doctrine because substantially similar claims had already been adjudicated.
4. Whether Campbell's parole-hearing claim was exhausted.
5. Whether new allegations raised for the first time in objections could be considered.
6. Whether Campbell was entitled to a certificate of appealability.

Disposition

denied