Holloway v. Devens Federal Medical Center - Petition Denied
Summary
The U.S. District Court for the District of Massachusetts denied James Holloway's petition for a writ of mandamus against Devens Federal Medical Center. The court found that Holloway failed to establish entitlement to mandamus relief regarding alleged interference with legal mail and retaliation by correctional officers.
What changed
The U.S. District Court for the District of Massachusetts, in the case of James Holloway v. Devens Federal Medical Center (Docket No. 26-10831-LTS), denied the petitioner's request for a writ of mandamus. The court determined that Holloway, a federal prisoner, did not sufficiently establish grounds for mandamus relief concerning his claims of interference with legal mail and alleged retaliation by correctional officers.
This decision dismisses the action. As this is a denial of a petition and not a new regulatory requirement or enforcement action with penalties, there are no immediate compliance actions or deadlines for regulated entities. The ruling pertains specifically to the petitioner's case and the application of 28 U.S.C. § 1361.
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Feb. 18, 2026 Get Citation Alerts Download PDF Add Note
James Holloway v. Devens Federal Medical Center
District Court, D. Massachusetts
- Citations: None known
- Docket Number: 1:26-cv-10831
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
)
JAMES HOLLOWAY )
Petitioner, )
)
v. ) Civil No. 26-10831-LTS
)
DEVENS FEDERAL MEDICAL CENTER, )
)
Respondent. )
)
MEMORANDUM AND ORDER
February 18, 2026
SOROKIN, J.
For the reasons set forth below, the petition is denied and this action dismissed because
petitioner fails to establish that he is entitled to mandamus relief.
I. Background
On February 17, 2026, James Holloway, a federal prisoner now in custody at FMC Devens,
filed a pro se petition for writ of mandamus pursuant to 28 U.S.C. § 1361 against “Devens Federal
Medical Center” seeking to “[c]ompel officers of the United States to perform duties.” Docket
No. 1. As best can be gleaned from the petition, Holloway complains that correctional officers
both interfered with Holloway’s efforts to mail legal documents to the United States Court of
Appeals for the Sixth Circuit and retaliated against Holloway through verbal threats. Id. Through
this action, Holloway seeks to have federal officers “gather evidence from Federal Medical Center
Devens on such electronic report system at such facility [including] reports sent to psychology of
what is exculpatory evidence.” Id. at 1. Among other things, Holloway states that “Unit Manager
Mr. Patornic has decided to retaliate [by verbally threatening Holloway]. Id. Attached to the
petition is a “witness statement.” Docket No. 1-1.
II. Standard of Review
Preliminary screening is mandated by the Prison Litigation Reform Act, which requires
federal courts to screen prisoner complaints seeking relief against a governmental entity, officer,
or employee. 28 U.S.C. § 1915A(a). The Court must dismiss a complaint or a portion thereof if
the prisoner has raised claims that (1) are legally frivolous or malicious; (2) fail to state a claim on
which relief can be granted; or (3) seek monetary relief from a defendant who is immune from
such relief. See 28 U.S.C. § 1915A(b). When making that determination, the Court must accept
the truth of the factual allegations contained in the complaint, and it may consider the documents
attached to the complaint. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).
In addition, federal courts possess certain “‘inherent powers,’ not conferred by rule or
statute, ‘to manage their own affairs so as to achieve the orderly and expeditious disposition of
cases.’” Goodyear Tire & Rubber Co. v. Haeger, 581 U.S. 101, 107 (2017) (quoting Link v.
Wabash R.R. Co., 370 U.S. 626, 630-31 (1962)). Those powers include the power to dismiss
frivolous or malicious actions, regardless of the status of the filing fee. See Mallard v. United
States Dist. Ct., 490 U.S. 296, 307-308 (1989); Brockton Sav. Bank. v. Peat, Marwick, Mitchell &
Co., 771 F.2d 5, 11 n.5 (1st Cir. 1985). As used in this context, “frivolous” does not refer to the
subjective intent of a litigant. Axcella Building Realty Trust v. Thompson, No. 23-40151-DHH, 2024 WL 474539, at n. 2 (D. Mass. Jan. 25, 2024). “Rather, in legal parlance, a pleading is
‘frivolous’ if it ‘lacks an arguable basis either in law or in fact.’” Id. (quoting Neitzke v. Williams, 490 U.S. 319, 325 (1989)).
Because Holloway is proceeding pro se, the Court will construe his petition generously.
See Haines v. Kerner, 404 U.S. 519, 520 (1972); Rodi v. New Eng. Sch. of Law, 389 F.3d 5, 13 (1st Cir. 2004). However, as set forth below, petitioner’s allegations are insufficient to state a
claim for mandamus relief.
III. Discussion
The common-law writ of mandamus, as codified in 28 U.S.C. § 1361, provides that:
[t]he district courts shall have original jurisdiction of any action in the nature of mandamus
to compel an officer or employee of the United States or any agency thereof to perform a
duty owed to the plaintiff. 28 U.S.C. § 1361. The writ of mandamus “is one of the most potent weapons in the judicial
arsenal,” but is granted only in “extraordinary situations.” Ramírez-De Arellano v. United States, 442 F.Supp.3d 499, 502 (D. Puerto Rico 2020) (citing and quoting United States v. Jicarilla
Apache Nation, 564 U.S. 162, 206 n.11 (2011); See In re Bushkin Associates, Inc., 864 F.2d 241,
245 (1st Cir. 1989)).
The party seeking a writ of mandamus must establish “that there is a clear entitlement to
the relief requested, and that irreparable harm will likely occur if the writ is withheld.” In re
Cargill, Inc., 66 F.3d 1256 at 1260 (1st Cir. 1995). Both the Supreme Court and the First Circuit
Court of Appeals have held unequivocally that a mandamus action may not circumvent or serve
as a substitute for an appeals process. Cheney v. U.S. Dist. Court for Dist. of Columbia, 542 U.S.
367, 381 (2004) (“[T]he writ will not be used as a substitute for the regular appeals process[.]”)
(citing Ex parte Fahey, 332 U.S. 258, 260 (1947)); In re JP Morgan Chase Bank, 799 F.3d 36, 38 (1st Cir. 2015).
Here, the petition does not name an officer or employee as respondent. Rather, the medical
center is identified as the respondent. In addition, Holloway has not demonstrated a clear
entitlement to relief. The Bureau of Prisons has an established "Administrative Remedy Program"
through which inmates "may seek formal review of an issue which relates to any aspect of their
confinement" except issues specifically exempted elsewhere, which are not relevant here. See 28
C.F.R. § 542.10, § 542.12. The program includes several levels, including two avenues of appeal.
See 28 C.F.R. §§ 542.13-542.15.
In light of the nature of the claims, the Court finds that amendment would likely be futile.
Garayalde-Rijos v. Municipality of Carolina, 747 F.3d 15, 23 (1st Cir. 2014) (explaining that sua
sponte dismissal is appropriate only when it is crystal clear that the plaintiff cannot prevail and
that amending the complaint would be futile).
Accordingly, and pursuant to 28 U.S.C. § 1915A(b), the action will be dismissed for failure
to state a claim upon which relief can be granted.
IV. Conclusion
In accordance with the foregoing, the Court hereby orders that:
1. The petition is DENIED and this action is DISMISSED pursuant to 28 U.S.C. §
1915A(b)(1) and the Court’s inherent power.
- The pending motions are DENIED.
The clerk shall enter a separate order of dismissal
SO ORDERED./s/ Leo T. Sorokin Leo T. Sorokin United States District Judge
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