Jason James Hyatt v. Josh Kaul, Wisconsin Attorney General, Jared Hoy, Wisconsin DOC Secretary, Troy Enger, Wisconsin DCC Administrator, and Anya Kauffman, Wisconsin DCC Probation and Parole Agent

Summary

The United States District Court for the Western District of Wisconsin ordered Jason James Hyatt to file an amended petition for habeas corpus under 28 U.S.C. § 2254. The court identified deficiencies concerning the proper respondent, required petition information and form, exhaustion of state remedies, timeliness, and the showing required under § 2254(d). Hyatt was given until July 1, 2026, to amend and was warned that failure to do so could result in dismissal.

Holdings

1. A § 2254 petitioner must name the state officer who has custody of the petitioner, and listing multiple individuals without identifying the specific custodian fails to satisfy Rule 2(a).
2. A § 2254 petition must state all available grounds for relief and the facts supporting each ground and must substantially follow the required federal or local form.
3. A state prisoner seeking federal habeas relief must demonstrate that available state remedies were exhausted by fully and fairly presenting the federal claims through one complete round of state-court review, and must address the federal habeas statute of limitations.
4. When a state court has adjudicated a claim on the merits, a federal habeas petitioner must show that the state decision was contrary to or involved an unreasonable application of clearly established Supreme Court law, or rested on an unreasonable determination of the facts.

Questions Presented

1. Whether the petition sufficiently identified the state official having custody of Hyatt as required by Rule 2(a) of the Rules Governing Section 2254 Cases.
2. Whether the petition complied with Rule 2(c) and Rule 2(d) by stating all grounds for relief, the facts supporting each ground, and using the required petition form.
3. Whether the petition demonstrated exhaustion of available state remedies and compliance with the one-year federal habeas statute of limitations.
4. Whether Hyatt showed that any state-court merits adjudication satisfied the demanding standard for federal relief under 28 U.S.C. § 2254(d).
5. Whether Hyatt should be permitted to cure the pleading deficiencies by filing an amended petition and supporting brief.

Disposition

other