## Facts

- After the September 11, 2001 attacks, U.S. forces captured non-citizens in Afghanistan alleged to be associated with the Taliban or al-Qaeda and transported them to the U.S. Naval Base at Guantánamo Bay, Cuba, where they were confined at “Camp X-Ray.”
- A group of clergy, lawyers, and professors, along with named individuals, filed a federal habeas corpus petition claiming to act as “next friends” for the detainees.
- The petition alleged the detainees were held without due process, without notice of accusations, without counsel, and in violation of the U.S. Constitution and the Third Geneva Convention.
- Petitioners asserted federal judicial authority existed because the United States exercised jurisdiction and control over Guantánamo Bay under a lease with Cuba.
- The government moved to dismiss the petition.

## Issues

1. Whether petitioners satisfied the requirements for next-friend standing to seek habeas relief on behalf of detainees.
2. Whether a federal district court had subject-matter jurisdiction under 28 U.S.C. § 2241 to consider habeas petitions for non-citizens detained at Guantánamo Bay.
3. Whether the case could be transferred to another federal district court if the filing court lacked jurisdiction or was an improper forum.

## Decision

- The court granted the government’s motion to dismiss.
- The court held petitioners lacked next-friend standing because they did not satisfy the requirements for litigating on behalf of the detainees.
- The court held it lacked habeas jurisdiction under § 2241 for non-citizens detained at Guantánamo Bay, treated as outside U.S. territorial habeas reach for statutory purposes.
- The court denied transfer, concluding no federal district court could hear the petition on the asserted habeas theory and transfer would be futile.

## Legal Principles

- Next-friend standing in habeas is limited and requires (1) a satisfactory explanation why the real party in interest cannot litigate and (2) a would-be next friend who is dedicated to the detainee’s best interests, typically supported by a significant, preexisting relationship.
- A generalized interest in lawful government action does not establish next-friend standing to litigate for unknown detainees.
- Under the court’s reading of § 2241 and then-controlling habeas doctrine, territorial and custodian-based limits could foreclose habeas jurisdiction when detainees and their immediate custodians were located outside any federal judicial district.
- Transfer under 28 U.S.C. § 1631 is unavailable if the action could not have been brought in the proposed transferee court.

## Conclusion

The court dismissed a purported next-friend habeas petition challenging the confinement of non-citizens at Guantánamo Bay because the petitioners failed to establish next-friend standing and, in any event, the court concluded § 2241 did not permit habeas jurisdiction for detainees held at Guantánamo; the court also denied transfer on the ground that no federal district court could entertain the petition as filed.


Coalition of Clergy v. Bush, 189 F. Supp. 2d 1036 (C.D. Cal. 2002)