Slater v. Crawford - Next Friend Habeas Petition Denied, Immigration Detention
Summary
The Eastern District of Virginia denied without prejudice and dismissed a habeas corpus petition filed by Adrienne Slater as 'next friend' on behalf of Jeff Crawford, an immigration detainee held at the Farmville Detention Center. The court found the petition procedurally defective because Crawford did not sign any submissions under penalty of perjury as required by Rule 2(c)(5) of the Rules Governing §2254 Cases. The Clerk is directed to mail Crawford a standardized § 2241 petition form and a copy of this opinion to the Farmville Detention Center so he may refile personally if he wishes.
“Accordingly, the Petition (ECF No. 1) will be DENIED WITHOUT PREJUDICE, and the action will be DISMISSED.”
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What changed
The court denied the petition without prejudice because it was filed by a 'next friend' without the detainee's own signature. Rule 2(c)(5) of the Rules Governing §2254 Cases requires petitions be signed under penalty of perjury by the petitioner or an authorized person, and the Advisory Committee Notes establish that courts must apply third-party 'next friend' standing analysis to determine actual authorization. The court also noted that a next friend does not become a party to the action but simply pursues the cause on behalf of the detainee. Any future § 2241 petition must be filed directly by the detainee himself, using a standardized form the Clerk will provide.
Immigration detainees and their counsel should note that habeas petitions filed by third parties—regardless of the relationship—must include the detainee's personal signature under penalty of perjury to survive this procedural defect. Detainees at Farmville or similar facilities who wish to pursue federal habeas relief should ensure they sign their own petitions or formally authorize counsel under 28 U.S.C. § 2242.
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Apr 24, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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April 21, 2026 Get Citation Alerts Download PDF Add Note
IN RE: JEFF CRAWFORD, et al.
District Court, E.D. Virginia
- Citations: None known
- Docket Number: 3:26-cv-00309
Precedential Status: Unknown Status
Trial Court Document
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
Petitioner,
v. Civil Action No. 3:26cv309
JEFF CRAWFORD, ef ai.,
Respondents.
MEMORANDUM OPINION
The Court has received a Petition for Writ of Habeas Corpus filed on behalf of Petitioner,
challenging his immigration detention. (‘“Petition,” ECF No. 1.) Adrienne Slater, filed the
Petition for Petitioner, purportedly as a “next friend.” Petitioner did not sign any of the
submissions.
Rule 2(c)(5) of the Rules Governing §2254 Cases requires that petitions pursuant to 28
U.S.C. § 2254 “be signed under penalty of perjury by the petitioner or by a person authorized to
sign it for the petitioner under 28 U.S.C. § 2242.” Rules Governing § 2254 Cases in U.S.
District Courts, Rule 2(c)(5).! The Advisory Committee Notes to Rule 2(c) explain: “The
Committee envisions that the courts will apply third-party, or ‘next-friend,’ standing analysis in
deciding whether the signer was actually authorized to sign the petition on behalf of the
petitioner.” Jd, Advisory Committee Notes, 2004 Amend. “[A] next friend does not himself
become a party to the habeas corpus action in which he participates, but simply pursues the cause
' Rule 1(b) of the Rules Governing § 2254 Cases permits this Court to apply the Rules
Governing § 2254 Cases to petitions under 28 U.S.C. § 2241. Rule 1(b), Rules Governing
§ 2254 Cases; see Aguayo v. Harvey, 476 F.3d 971, 976 (D.C. Cir. 2007).
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Accordingly, the Petition (ECF No. 1) will be DENIED WITHOUT PREJUDICE, and
the action will be DISMISSED.
Nevertheless, in order to expedite any further § 2241 petition filed by Petitioner himself,
the Clerk is DIRECTED to mail a copy of this Memorandum Opinion, Order, and a standardized
form for filing a § 2241 petition to Petitioner at the Farmville Detention Center.’ If Petitioner
wishes to pursue a § 2241 petition, he should complete and return the form to the Court.
Petitioner must sign the form himself. Any § 2241 petition will be opened as a new civil action.
An appropriate Final Order shall accompany this Memorandum Opinion.
Date: la | 2Le M. Hanna Cc
Richmond, Virginia Chief United/States District Judge
The Court should mail this Memorandum Opinion and Order and a standardized § 2241
petition form to Petitioner at the Farmville Detention Center with the “A” number, “035362948.”
(See ECF No. 1, at 1.)
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