Discretionary Provision of Certified Records in State Prisoners’ Federal Habeas Actions

Introduction

Maria Navarro-Martin v. State of Florida addresses when and under what authority a federal district court must—or may—provide a state prisoner with certified copies of court records at no cost in connection with federal habeas proceedings. Petitioner-Appellant Maria Navarro-Martin, a Florida state inmate proceeding pro se, sought post-conviction relief from her state court judgment through federal habeas petitions mis-styled under 28 U.S.C. § 2241, and subsequently requested the district court clerk to furnish certified copies of her state conviction record free of charge. She invoked two statutory provisions—18 U.S.C. § 3662(b) (creation of a federal repository for conviction records) and 28 U.S.C. § 2250 (free copies of records for in forma pauperis habeas petitioners)—as the basis for her request. The Eleventh Circuit affirmed the district court’s denial of that request and clarified the scope and applicability of those statutes.

Summary of the Judgment

The Eleventh Circuit, in a per curiam opinion, held:

18 U.S.C. § 3662(b) does not obligate a federal court to provide a state conviction record because it applies only to convictions in federal or specified territorial courts, not state courts. Even if § 3662(b) applied, it authorizes certified records only upon request of a court or law-enforcement/corrections officer, not a prisoner pro se.
28 U.S.C. § 2250 concerns the free provision of records to petitioners permitted to proceed in forma pauperis, but the district court never granted that status in the second habeas case. Moreover, § 2250 is discretionary, not mandatory, even for in forma pauperis petitioners.
Accordingly, the district court did not err in refusing to furnish Navarro-Martin with certified copies at no cost, and its order was affirmed.
The Court also noted it lacked jurisdiction to review the earlier § 2241 petition dismissal because the appeal was untimely.

Analysis

Precedents Cited

Thomas v. Crosby, 371 F.3d 782 (11th Cir. 2004): Holds that a state prisoner in custody under a state court judgment cannot bypass the procedural requirements of 28 U.S.C. § 2254 by labeling a petition as § 2241. The Eleventh Circuit reaffirmed that § 2254 controls collateral challenges to state convictions, regardless of the label.
Bellizia v. Florida Dep’t of Corrections, 614 F.3d 1326 (11th Cir. 2010): Establishes that pro se filings must be construed liberally but does not alter substantive requirements for habeas relief or procedural statutes governing filing fees and record requests.
Green v. Drug Enforcement Administration, 606 F.3d 1296 (11th Cir. 2010): Confirms that a notice of appeal filed beyond the 30-day deadline deprives the Court of jurisdiction to review the underlying district‐court order.
United States v. Jackson, 58 F.4th 1331 (11th Cir. 2023): Clarifies the standard of de novo review applicable to statutory interpretation questions, which the Court applied in analyzing §§ 3662 and 2250.

Legal Reasoning

The Court began with de novo review of the statutes invoked by Navarro-Martin. It examined 18 U.S.C. § 3662(b), which instructs federal courts to send certified records of certain federal convictions or collateral‐review determinations to a Department of Justice repository, and § 3662(c), which limits distribution of those records to courts or law-enforcement/corrections officers. Because Navarro-Martin was convicted in a Florida state court—outside the list of federal and territorial courts covered by § 3662(b)—the statute imposed no obligation on the district court to provide her with certified copies. Even if it did, § 3662(c) restricts free certified copies to official requestors, not to private litigants.

Turning to 28 U.S.C. § 2250, the Court noted that it applies only when a petitioner has been authorized to proceed in forma pauperis in a habeas action. Navarro-Martin had not obtained that status in her second petition, rendering § 2250 inapplicable. Moreover, the statute grants district courts discretion in furnishing certified copies, rather than imposing a mandatory duty.

Having found both statutes inapplicable or discretionary, the Eleventh Circuit concluded that the district court properly denied the request.

Impact

This decision clarifies several points for future federal habeas practice:

State prisoners seeking collateral review must invoke § 2254, not § 2241, and comply with its procedural rules.
Requests for free certified copies of records under 18 U.S.C. § 3662 are limited to qualifying federal convictions and official requestors, not private inmates.
Under 28 U.S.C. § 2250, only inmates granted in forma pauperis status may request free certified copies, and even then, courts retain discretion.
Litigants should pay careful attention to appeal deadlines to preserve their right to appellate review.

Complex Concepts Simplified

Habeas Corpus: A legal proceeding by which a prisoner can challenge the legality of their detention.
In Forma Pauperis: A status allowing indigent litigants to proceed without payment of court fees or costs.
Collateral Review: Post-conviction proceedings (e.g., habeas petitions) challenging the validity of a criminal conviction or sentence.
Certified Copy: A court‐sealed and signed reproduction of a document or record, affirming its authenticity.
Federal Repository (18 U.S.C. § 3662): A Department of Justice database of conviction records for certain federal offenses, maintained for law enforcement use.

Conclusion

Maria Navarro-Martin v. State of Florida establishes that federal district courts are not required to provide state prisoners with free certified copies of state conviction records under 18 U.S.C. § 3662 or 28 U.S.C. § 2250, absent proper statutory eligibility. The decision reaffirms the primacy of § 2254 for collateral challenges to state convictions, reinforces the discretionary nature of § 2250 even for indigent petitioners, and limits § 3662’s application to federal convictions and official requestors. This clarification will guide courts and litigants in managing record requests in federal habeas proceedings and avoid procedural missteps in appeals.