RANSOM v. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Memorandum Opinion re 4 Order on Petition for Writ of Habeas Corpus. Signed by Judge James E. Boasberg on 4/6/17. (lcjeb2)
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Civil Action No. 17-375 (JEB)
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA,
Pro se Petitioner Joseph Ransom brings this action seeking a writ of habeas corpus,
money damages, and a declaration that Public Law 80-772 (from 1947) is “unconstitutional and
void abinitio.” ECF No. 1 (Petition) at 11, 33. More specifically, he asserts that Congress
passed Public Law 80-772, which, in part, grants jurisdiction to federal district courts over “all
offenses against the laws of the United States,” without the congressional quorum required by
the Constitution. Id. at 11. Because Ransom was apparently tried in such a court under such a
law, he argues that this unidentified federal district court lacked jurisdiction to oversee his trial,
conviction, and eventual imprisonment in a federal correctional institution in Littleton, Colorado.
Id. To right this purported wrong, he asks that this Court now release him from incarceration,
declare him innocent, award him “$3,500 per day of [his] illegal incarceration,” and order that he
not pay taxes on such amount (or ever again). Id. at 33.
The gravamen of Ransom’s Petition is that his conviction should be overturned because
the jurisdictional statute under which he was convicted is unconstitutional. “The general rule is
that a motion under 28 U.S.C. § 2255 is the exclusive means by which a federal prisoner may
test the legality of his detention.” Stephens v. Herrera, 464 F.3d 895, 897 (9th Cir. 2006)
(citation omitted). A prisoner’s challenge to the jurisdiction of the federal court imposing his
sentence must thus be raised as a motion under § 2255 to vacate, set aside, or correct his
sentence. Id.; see also Taylor v. U.S. Bd. of Parole, 194 F.2d 882, 883 (D.C. Cir. 1952) (stating
that attack on constitutionality of statute under which defendant was convicted and sentenced is
properly pursued by motion under 28 U.S.C. § 2255). Such a motion, moreover, must be filed in
the court that imposed the sentence unless the prisoner can show that such a “remedy by motion
is inadequate or ineffective to test the legality of his detention.” 28 U.S.C. § 2255(e); see
Stephens, 464 F.3d at 897.
Ransom’s claim for relief has several fatal problems. First, he offers no proof that this is
the appropriate forum for adjudication of his Petition; in other words, this Court has no idea
whether he was convicted and sentenced here. Ransom, moreover, makes no claim that a motion
in his sentencing court – wherever located – would be inadequate or ineffective to address his
Finally, even if he could bring this action here, his Petition must still be dismissed as
frivolous. As other courts have explained in great detail, his contention that Congress did not
lawfully pass Public Law 80-772 in 1947 is “utterly baseless” and nothing more than a
widespread “[jailhouse] rumor.” Goodman v. Levi, No. 07-4838, 2007 WL 4241894, at *2 (E.D.
Pa. Nov. 29, 2007). In fact, dozens of federal district courts from around the country have
already uniformly dismissed identical claims as wholly frivolous. Cardenas-Celestino v. United
States, 552 F. Supp. 2d 962, 966-67 (W.D. Mo. 2008) (collecting cases). This Court, without
repeating the whole sordid tale here, concurs in the exhaustive efforts made by these courts to
debunk this jailhouse theory as lacking in any merit.
To the extent that Ransom also seeks damages for his allegedly illegal confinement,
moreover, this claim also fails. As the Supreme Court instructs:
[I]n order to recover damages for allegedly unconstitutional
conviction or imprisonment, or for other harm caused by actions
whose unlawfulness would render a conviction or sentence
invalid[,] . . . plaintiff must prove that the conviction or sentence has
been reversed on direct appeal, expunged by executive order,
declared invalid by a state tribunal authorized to make such
determination, or called into question by a federal court’s issuance
of a writ of habeas corpus.
Heck v. Humphrey, 512 U.S. 477, 486-87 (1994). Because Ransom does not demonstrate that
his conviction or sentence has been reversed or otherwise invalidated, his claim for damages
must also be dismissed. See, e.g., Johnson v. Williams, 699 F. Supp. 2d 159, 171 (D.D.C. 2010),
aff’d sub nom. Johnson v. Fenty, No. 10-5105, 2010 WL 4340344 (D.C. Cir. Oct. 1, 2010).
The Court will, accordingly, dismiss the Petition because it does not appear that this
district is the appropriate forum and because Ransom otherwise fails to state a claim upon which
relief can be granted. See 28 U.S.C. §§ 1915(e)(2)(B)(ii), 1915A(b)(1). A contemporaneous
Order so stating will be issued today.
/s/ James E. Boasberg
JAMES E. BOASBERG
United States District Judge
Date: April 6, 2017
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