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Court Discusses Concept of Settled Jurisprudence


This is an appealed case from the US District Court for Georgia. The district court dismissed the appellant’s complaint on the basis of the application of a settled jurisprudence in his case, which “held that a state prisoner’s claim for damages is not cognizable if ‘a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence,’ unless the prisoner can demonstrate that the conviction or sentence has previously been invalidated.” A New York Criminal Lawyer said the issue raised in the appeal is whether or not a claim for damages and declaratory relief filed by the state prisoner is barred by the rule on the settled jurisprudence. The state prisoner in filing his claim challenged the validity of the procedures of his extradition from Georgia to New York. The appellate court reversed the dismissal of the district court.

The accused was serving a twenty-five year sentence at the federal prison located in Kansas. The appellant was later on extradited to Suffolk County, New York and was indicted of another criminal suit for which he served another twenty-five years to life. In the year of 2000, upon the lapse of time of his release, the convicted appellant was arrested with protest on his part because he was not given the signed extradition warrant to waive his extradition rights or habeas hearing and then he was extradited to New York to serve sentence for another criminal conviction.

As a consequence, he filed a verified complaint at New York District stating defendants’ violations of his constitutional right and seeking injunctive relief and claim for compensatory damages. The action was referred back to Georgia District Court, which dismissed the suit for failure to state a claim wherein relief could be granted pursuant to a statute. The major contention of the district court is finding the action as premature since the appellant failed to allege that his sentence or conviction for the crime charge was declared invalid. Thus, this appeal is filed.

A Bronx Criminal Lawyer said the constitutional violations set forth in the complaint were plaintiff’s denial of right to a pre-extradition habeas corpus hearing, the right to be extradited by government agents and not of a private entity, and the right as to the issuance of warrant by the Governor. The contention of the district court is “that a state prisoner may not maintain an action if the direct or indirect effect of granting relief would be to invalidate the state sentence he is serving.” Or to state otherwise, the district court shall proceed with the hearing of the suit if any ruling would not effectuate the invalidity of a prior judgment of court. For this reason, the jurisprudence applied in this case which barred the complaint shall not be merited consideration for purely procedural claims without contest as to the validity of the judgment itself.

The issue presented in the complaint is grounded upon the validity of the procedures of his extradition from one state to another, thus, warranting him claim for damages. Consequently, a New York Sex Crimes Lawyer said that such an issue does not cause the invalidity of the judgment, which was the reason of why he was extradited to begin with. In addition, extradition procedures are not directly or indirectly related to the guilt or innocence of the extradited individual.

Thus, the appellate court arrived at the conclusion that the violations of the extradition procedures asserted by the plaintiff had no relation to the question of guilt or innocence of the criminal and, as such, do not invalidate his conviction or sentence. Hence, plaintiff’s allegations do not entail the application of the jurisprudence used as basis for the dismissal of the complaint.

Accordingly, the appellate court found the dismissal of the plaintiff’s action by the district court was erroneous and remanded for further considerations.

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