Rumsfeld v. Padilla - 542 U.S. 426, 124 S. Ct. 2711 (2004)

Rule:

District courts are limited to granting habeas relief within their respective jurisdictions. 28 U.S.C.S. § 2241(a). Courts interpret this language to require nothing more than that the court issuing the writ have jurisdiction over the custodian.

Facts:

Respondent Padilla, a United States citizen, was brought to New York for detention in federal criminal custody after federal agents apprehended him while executing a material witness warrant issued by the District Court for the Southern District of New York in connection with its grand jury investigation into the September 11, 2001, al Qaeda terrorist attacks. While his motion to vacate the warrant was pending, the President issued an order to Secretary of Defense Rumsfeld designating respondent an "enemy combatant" and directing that he be detained in military custody. Respondent was later moved to a Navy brig in Charleston, S. C., where he has been held ever since. His counsel then filed in the Southern District a habeas petition under 28 U.S.C. § 2241, alleging that respondent’s military detention violated the Constitution, and named as respondents the President, the Secretary, and Melanie Marr, the brig's commander. The Government moved to dismiss, arguing that Commander Marr, as respondent’s immediate custodian, was the only proper respondent, and that the District Court lacked jurisdiction over her because she was located outside the Southern District. The district court held that the Secretary's personal involvement in respondent’s military custody rendered him a proper respondent, and that it could assert jurisdiction over the Secretary under New York's long-arm statute, notwithstanding his absence from the District. On the merits, the court accepted the Government's contention that the President has authority as Commander in Chief to detain as enemy combatants citizens captured on American soil during a time of war. The Second Circuit agreed that the Secretary was a proper respondent and that the Southern District had jurisdiction over the Secretary under New York's long-arm statute. The appeals court reversed on the merits, however, holding that the President lacked authority to detain Padilla militarily. A writ of certiorari was granted. 

Issue:

1. Did the United States District Court for the Southern District of New York have jurisdiction over the respondent’s habeas corpus petition? 
2. Did the United States District Court for the Southern District of New York have jurisdiction over the Secretary of Defense, notwithstanding his absence from the District? 

Answer:

1) No. 2) No.

Conclusion:

The United States Supreme Court reversed the judgment of the appellate court, holding that the habeas corpus jurisdiction was limited to the district in which the detainee was confined. The Court further held that the commander of the military confinement facility was the only proper custodial official for habeas purposes. The Court noted that the respondent detainee sought release from present physical confinement; thus, the recognized exceptions to the immediate custodian rule did not apply. Further, the court in the district where the petition was filed lacked jurisdiction over the commander since the commander was a resident of the district where confinement occurred. According to the Court, any unique circumstances of the case were insufficient to alter the traditional habeas corpus jurisdiction rules.