Ja’Don Malone v. Warden FNU Heidle

Summary

The United States District Court for the Western District of Tennessee denied Ja’Don Malone’s motion for an extension of time to submit an inmate trust account statement. The court determined that Malone’s claims were civil rights claims under 42 U.S.C. § 1983 rather than habeas claims under 28 U.S.C. § 2241, directed the Clerk to mail him the appropriate civil rights complaint form, and explained the applicable filing-fee requirements.

Holdings

1. Claims challenging the conditions of a prisoner's confinement must be pursued as civil-rights claims under 42 U.S.C. § 1983 rather than as habeas claims under 28 U.S.C. § 2241 when they do not challenge the validity or duration of confinement.
2. The motion for an extension of time to submit an inmate trust account statement for in forma pauperis treatment on the petition as a habeas action was denied; to pursue the claims as civil-rights claims, petitioner had to use the proper § 1983 complaint form and either pay the applicable filing fee or move for leave to proceed in forma pauperis.

Questions Presented

1. Whether petitioner's letter should be construed as a motion for an extension of time to submit an inmate trust account statement for in forma pauperis treatment.
2. Whether the asserted prison-conditions claims were properly brought under 28 U.S.C. § 2241 or instead had to be brought as civil-rights claims under 42 U.S.C. § 1983.
3. What filing-form and fee requirements petitioner had to satisfy if he wished to pursue the asserted civil-rights claims.

Disposition

other