Background
Robert Michael Ardis, a Florida prisoner proceeding pro se, petitioned the Fourth Circuit for a writ of habeas corpus seeking immediate release from state custody. The petition was submitted on June 25, 2026, and decided on June 30, 2026.
The court’s reasoning
The court explained that while 28 U.S.C. Section 2241(a) grants the Supreme Court, any justice thereof, district courts, and any circuit judge within their respective jurisdictions the power to grant writs of habeas corpus, it does not confer jurisdiction on courts of appeals. The court cited Dragenice v. Ridge to clarify that jurisdiction is limited to individual circuit judges, not the appellate court as a body. Although the court has the authority to transfer petitions under 28 U.S.C. Section 1631, it concluded that transfer was not in the interest of justice in this instance.
Writs of habeas corpus may be granted by the Supreme Court, any justice thereof, the district courts and any circuit judge within their respective jurisdictions.
28 U.S.C. Section 2241(a)
What it means going forward
The dismissal reinforces the jurisdictional limitation that federal appellate courts cannot directly grant habeas relief, requiring petitioners to seek relief from district courts or individual circuit judges.