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United States v. Crockett

November 18, 2004


Appeal from the Superior Court of the District of Columbia Criminal Division .(Hon. Jose M. Lopez, Trial Judge). F4385-97 & F9296-97.

Before Terry, Reid, and Washington, Associate Judges.

The opinion of the court was delivered by: Washington, Associate Judge.

Argued September 9, 2004

In this case, we must decide whether the Superior Court of the District of Columbia has jurisdiction to enforce treatment under the D.C. Youth Rehabilitation Act*fn1 ("Youth Act") on behalf of an offender sentenced under the Act, where the offender is neither incarcerated within the District of Columbia nor in the custody of D.C. officials. Appellant United States challenges the trial court's decision in which it ordered the Federal Bureau of Prisons ("BOP") to provide certain services to inmate appellee Wardell Crockett ("Crockett") under the Youth Act. The United States contends that the trial court lacked jurisdiction to take this action. We agree, and reverse the trial court's order.


A. Trial and Sentencing

After a bench trial, Crockett was convicted of assault,*fn2 kidnaping while armed,*fn3 four counts of assault with a dangerous weapon,*fn4 destroying property,*fn5 and two counts of first degree cruelty to children.*fn6 In May 1998, the trial court sentenced Crockett to up to fourteen years for his convictions.*fn7 Because Crockett was identified as an offender who possibly would benefit from such treatment, the trial court "committed [Crockett] to the custody of the Attorney General for treatment and supervision provided by the D.C. Department of Corrections" under the Youth Act.

Crockett was originally housed at the Lorton Correctional Complex in Lorton, Virginia. With the closure of the Lorton facility, however, Crockett was transferred to BOP custody. See D.C. Code 24-101 (b) (2001). The BOP placed Crockett at the United States Penitentiary in Terre Haute, Indiana ("USP Terre Haute"), where he is currently incarcerated.*fn8

B. Crockett's motion and trial court order

On January 11, 2002, Crockett filed a pro se motion in the Superior Court requesting that the trial court enforce certain treatment under the Youth Act on his behalf. In the motion, Crockett requested that he be placed in a youth rehabilitation facility pursuant to the Youth Act. After receiving the motion, the court appointed Crockett counsel from the D.C. Public Defender Service, who filed a subsequent motion incorporating Crockett's pro se motion. In this second motion, counsel for Crockett argued that, in addition to being segregated from the adult prison population, Crockett was in need of special learning needs testing. Should he receive these educational services, counsel argued, Crockett would be able to prepare for the General Educational Development ("GED") exam. Without special services, or the development of another treatment plan, counsel for Crockett argued that he would not be able to attain his GED, which was a prerequisite for qualifying for parole. The motion also stated that Crockett's transfer to USP Terre Haute did not invalidate the terms of his sentence under the Youth Act. In a footnote in the motion, counsel for Crockett alleged that the Superior Court's jurisdiction to hear this case was based on the Youth Act, D.C. Code § 23-110 (a), and § 16-1901 (a). The government opposed the motion, contending that the trial court lacked both personal and subject matter jurisdiction to hear the case because Crockett was now under BOP custody in Indiana.

On July 8, 2003, the trial court issued an order granting Crockett's motion to enforce the terms of his judgment and commitment order. The trial court ordered the BOP to "house Mr. Crockett only with other Youth Act prisoners," and "provide special learning needs testing and evaluation as well as develop an individualized rehabilitative treatment plan for Mr. Crockett." The court devoted a substantial part of the order to its finding of jurisdiction in the case, stating that Crockett's motion was "in essence a petition for a writ of habeas corpus and [] construe[d] it as such." Accordingly, the trial court relied on D.C. Code § 16-1901, the District's habeas corpus provision. The trial court rejected the government's argument that D.C. courts lack jurisdiction to review habeas petitions of prisoners incarcerated outside the District under this court's decision in Taylor v. Washington, 808 A.2d 770, 772 (D.C. 2002). The trial court stated that this case was distinguishable because Crockett's custodian is not the warden of the particular prison in which he is incarcerated, as in Taylor, but rather is deemed to be the Director of the Department of Corrections.

The trial court relied on additional statutory provisions to find jurisdiction. Specifically, the court stated that the Youth Act itself conferred jurisdiction because it allowed a sentencing judge to review a Youth Act offender's appeal from the Department of Corrections ("DOC") determination that the offender would derive "no further benefit" from treatment under the Youth Act. Because, the trial court held, the Department of Corrections made a de facto "no further benefit" finding by ignoring Crockett's Youth Act status, the trial court had jurisdiction to review the case. The trial court also relied on the "remedies section on attacking sentences" of D.C. Code § 23-110 and the All Writs Act, 28 U.S.C. § 1651 (a), as independent bases of jurisdiction.

The government appeals from ...

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