Hartfield v. Osborne, No. 15-20275 (5th Cir. 2015)
Annotate this CasePetitioner filed a petition for habeas corpus relief under 28 U.S.C. 2241, arguing that his right to a speedy trial had been violated by the State of Texas because the State had held him in prison for approximately thirty years without a valid state court judgment and without retrying him consistent with the mandate of the State’s highest criminal court. The district court denied the petition and issued a certificate of appealability as to whether special circumstances are present. Although petitioner was not in custody pursuant to a state court judgment when he originally filed his petition, he was convicted by a Texas state court following the district court’s decision. Because he has been convicted, any writ of habeas corpus granted by a federal court will necessarily free him from custody pursuant to a state court judgment. Therefore, 28 U.S.C. 2254 now applies to petitioner’s petition. The court dismissed the appeal because the existence of “special circumstances” is no longer relevant and because the court lacked jurisdiction over anything related to section 2254 based on the certificate of appealability issued by the district court.
The court issued a subsequent related opinion or order on January 20, 2016.
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